0001493152-18-000301.txt : 20180208 0001493152-18-000301.hdr.sgml : 20180208 20180108140913 ACCESSION NUMBER: 0001493152-18-000301 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20180108 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VirTra, Inc CENTRAL INDEX KEY: 0001085243 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-AMUSEMENT & RECREATION SERVICES [7900] IRS NUMBER: 931207631 STATE OF INCORPORATION: NV FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 7970 S. KYRENE ROAD CITY: TEMPE STATE: AZ ZIP: 85284 BUSINESS PHONE: 4809681488 MAIL ADDRESS: STREET 1: 7970 S. KYRENE ROAD CITY: TEMPE STATE: AZ ZIP: 85284 FORMER COMPANY: FORMER CONFORMED NAME: VIRTRA SYSTEMS INC DATE OF NAME CHANGE: 20020628 FORMER COMPANY: FORMER CONFORMED NAME: GAMECOM INC DATE OF NAME CHANGE: 19991103 CORRESP 1 filename1.htm

VIRTRA, INC.

7970 S. Kyrene Rd.

Tempe, AZ 85284

(480) 968-1488

January 8, 2018

Justin Dobbie

Legal Branch Chief, Office of Transportation and Leisure

Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C. 20549

Re:	VirTra, Inc.
	Offering Statement on Form 1-A
	Filed September 11, 2017
	File No. 024-10739

Acceleration Request

Requested Date: Wednesday, January 10, 2018

Requested Time: 12:00 PM Eastern Time

Dear Mr. Dobbie:

VirTra, Inc. (the “Company”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to declare the above-captioned Offering Statement on Form 1-A qualified at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable.

The Company hereby authorizes Craig D. Linder, who is an attorney with the Company’s outside legal counsel, Legal & Compliance, LLC, to orally modify or withdraw this request for acceleration.

The Company hereby acknowledges that:

	●	should the Commission or the staff of the Commission, acting pursuant to delegated authority, declare the filing qualified, it does not foreclose the Commission from taking any action with respect to the filing;

	●	the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing qualified, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

	●	the Company may not assert the staff comments and the declaration of qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Justin Dobbie

Securities and Exchange Commission

January 8, 2018

Page 2

The Company also agrees that it will only sell shares of its common stock pursuant to the subject Offering Statement in states where the offering is registered or where there is an applicable exemption from the applicable state’s securities law available.

The Company requests that it be notified of such qualification by a telephone call to Craig D. Linder at (561) 514-0936 or email to him at: clinder@legalandcompliance.com.

	VIRTRA, INC.

	By:	/s/ Robert D. Ferris
		Robert D. Ferris
		Chief Executive Officer