December 11, 2013
BY EDGAR
Jeffrey P. Riedler
Johnny Gharib
Daniel Greenspan
Securities and Exchange Commission
Division of Corporation Finance
Washington, DC 20549
Re: Medistem Inc.
Amendment No. 1 to Registration Statement on Form 10-12G Filed November 12, 2013
File No. 000-54999
Gentlemen:
We have received and reviewed, and we thank you for, the Staff’s comment letter dated December 9, 2013. Our responses are set forth below. In each case, we precede our response by repeating the Staff’s letter’s comment. Our responses are numbered to correspond with the numbering of the comments in the Staff’s letter.
Please consider our responses in conjunction with your review of our Form 10-12G/A amendment no. 3 (the “Amendment”), which we are filing simultaneously.
Intellectual Property, page 8
| 1. | STAFF’S COMMENT: We note your response to our prior comment 1 and your added disclosure in footnote (1) of the intellectual property section on page 9. Please revise this disclosure to also describe each party’s ability to terminate the agreement. |
REGISTRANT’S RESPONSE: We have amended this disclosure to include each party’s ability to terminate the agreement.
If you have any questions or if we can be assistance in your review, please contact me or John Salvador, our Chief Operating Officer, john.salvador@medisteminc.com, (626) 644-6092.
Sincerely,
/s/ Alan J. Lewis
Alan J. Lewis
Chief Executive Officer
