United States securities and exchange commission logo
July 13, 2020
Jill M. Taymans
Chief Financial Officer
Cryo-Cell International, Inc.
700 Brooker Creek Blvd., Suite 1800
Oldsmar, FL 34677
Re: Cryo-Cell
International, Inc.
Form 10-K for the
Fiscal Year Ended November 30, 2019
Filed February 28,
2020
File No. 000-23386
Dear Ms. Taymans:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended November 30, 2019
Item 9A. Controls and Procedures, page 67
1. We note under
Evaluation of Disclosure Controls and Procedures that you concluded
your disclosure
controls and procedures are not effective. However, under
Management s
Report on Internal Control over Financial Reporting you state the
Company s disclosure
controls and procedures and internal controls over financial
reporting were
effective. Please note that an assessment of internal control over financial
reporting is separate
and distinct from an assessment of disclosure controls and
procedures. Please
address the following:
tell us how you
concluded your internal control over financial reporting
was effective as of
November 30, 2019 considering that your disclosure controls and
procedures were not
effective as of the same date;
amend your Form
10-K to provide management's evaluation and assessment of your
Jill M. Taymans
Cryo-Cell International, Inc.
July 13, 2020
Page 2
internal control over financial reporting as defined in Rules
13a-15(f) and 15d-15(f)
of the Exchange Act and clearly state whether such controls are
effective or not
effective;
include in the amended filing a discussion of any identified
material weaknesses;
explain to us the changes implemented in your disclosure
controls and procedures
that enabled management to conclude that they were effective as
of February 29,
2020 as disclosed in your Form 10-Q.
Refer to Items 307 and 308 of Regulation S-K.
2. Please tell us why you continue to include the disclosures related to
the PrepaCyte Form
8-K that was filed on July 16, 2015.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
Please contact Eric Atallah at (202) 551-3663 or Lynn Dicker, Senior
Accountant, at
(202) 551-3616 with any questions.
FirstName LastNameJill M. Taymans Sincerely,
Comapany NameCryo-Cell International, Inc.
Division of
Corporation Finance
July 13, 2020 Page 2 Office of Life
Sciences
FirstName LastName