-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, N7SqyJDrnG329VcuT1SW+/WoeB7vV2R52IeDC6m/TtvDzseVwxURHqqXfY6g6ymT Lkgzpf9Q46k+82pz1tbcOQ== 0001168220-07-000032.txt : 20070522 0001168220-07-000032.hdr.sgml : 20070522 20070402150821 ACCESSION NUMBER: 0001168220-07-000032 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20070402 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ULURU INC. CENTRAL INDEX KEY: 0001168220 STANDARD INDUSTRIAL CLASSIFICATION: PHARMACEUTICAL PREPARATIONS [2834] IRS NUMBER: 412118656 STATE OF INCORPORATION: NV FISCAL YEAR END: 1206 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 4452 BELTWAY DRIVE CITY: ADDISON STATE: TX ZIP: 75001 BUSINESS PHONE: 214-905-5145 MAIL ADDRESS: STREET 1: 4452 BELTWAY DRIVE CITY: ADDISON STATE: TX ZIP: 75001 FORMER COMPANY: FORMER CONFORMED NAME: OXFORD VENTURES INC DATE OF NAME CHANGE: 20020225 CORRESP 1 filename1.htm Reply letter to SEC, dated April 2, 2007
ULURU Inc.
4452 Beltway Drive
Addison, TX 75001
Phone: 214-905-5145 ● Fax: 214-905-5130



April 2, 2007


Via EDGAR and Federal Express


United States Securities Exchange Commission
Division of Corporate Finance
Washington, DC 20549
Attention: J. Todd Sherman


Re:
ULURU Inc.
 
Item 4.01 Form 8-K
 
Filed on March 29, 2007
 
File Number No. 000-49670
   

Dear Mr. Sherman:

ULURU Inc., a Nevada corporation (the "Company"), hereby sets forth below its response to comment of the staff (the "Staff") of the Division of Corporation Finance of the Securities and Exchange Commission (the "Commission") contained in your letter dated April 2, 2007 (the "Comment Letter").

For ease of reference, the comment contained in the Comment Letter is printed below in bold print, followed by the Company's response.

1.
Please amend the fifth paragraph of your filing to cover the interim period from the date of your last audited financial statements through the date your former accountant was dismissed as required by Item 301(a)(1)(iv) of Regulation S-B.
 
In response to the Staff's comment, the Company has amended its March 29, 2007 Form 8-K and on the date hereof filed a Form 8-K/A to cover the interim period through the date its former accountant was dismissed. The revised Form 8-K/A is available on EDGAR and clean and marked copies of it, showing changes from the March 29, 2007 Form 8-K, are enclosed herewith.

The Company hereby acknowledges that (i) the Company is responsible for the adequacy and accuracy of the disclosure in the filing, (ii) Staff comments or changes in disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing and (iii) the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
 
*  *  *

Should you wish to discuss the enclosed materials or the contents of this letter at any time, please do not hesitate to contact the undersigned at (214) 905-5145 or John J. Concannon III, Esq. of Bingham McCutchen LLP, the Company's legal counsel, at (617) 951-8874.

Very truly yours,

/s/ Terrance K. Wallberg

Terrance K. Wallberg
Chief Financial Officer



cc:
Kerry P. Gray (ULURU Inc.)
 
John J. Concannon III, Esq.
 

 


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