December 2, 2015
Division of Corporation Finance
SECURITIES AND EXCHANGE COMMISSION
100 F Street NE
Washington D.C. 20549
Attn:
John Reynolds, Asst. Director
Michael Killoy, Staff Attorney
Jim Lopez, Staff Attorney
Steve Lo, Staff Accountant
Craig Arakawa, Staff Accountant
Re:
Wadena Corp. (“Registrant”)
Amendment No. 2 to Registration Statement on Form S-1
Filed on September 18, 2015
File No. 333-207047
Gentlepersons:
The Registrant hereby files its Amendment No. 2 to Registration Statement on Form S-1 (“Amendment No. 2”). The Amendment No. 2 has been revised in accordance with the Commission’s November 20, 2015 comment letter (“Comment Letter”).
To assist the staff in its review of Registrants responses, we have provided a copy of Amendment No. 2 “marked to show changes”, and our responses below correspond to each comment number in the Comment Letter.
Business, page 12
1.
In response to your comment we have added disclosure to pages 4 and 12.
Financial Statements, Page 31
2.
In accordance with your comment we have include are responses to your prior comments 9 and 10 in the interim financial statements in the Amendment No. 2.
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December 2, 2015
Re:
Wadena Corp. (“Registrant”)
Page 2 of 2
Enclosed with this response is a letter from the President of the Registrant acknowledging, among other things, the Registrant’s responsibility for the adequacy and accuracy of the disclosure in this filing.
We believe that we have responded to all of your comments fairly and reasonably. Please contact the undersigned as soon as possible should you have any further questions or comments.
Thank you in advance for your courtesies and cooperation.
Very truly yours,
BARNETT & LINN
William B. Barnett
WBB: scc
cc/ Mr. St. George, President & CEO