SEC Division of Corporation Finance no-action letter: Sielox, Inc.

HERRICK
NEW YORK
NEWARK
PRINCETON
Rule 12h-3 under the Securities Exchange Act of 1934;
Section 15(d) of the Securities Exchange Act of 1934
VIA E-MAIL
Office of Chief Counsel
100 F Street, N.E.
Washington, D.C. 20549
Email: cftetters@sec.gov
Re: Sielox, Inc. (File No. 000-29423)
Ladies and Gentlemen:
On behalf of our client Sielox, Inc., a Delaware corporation ("Sielox"), we hereby request that the Staff of the Division of Corporation Finance (the "Staff') of the U.S. Securities and Exchange Commission ("the "Commission") confinn that it concurs with Sielox's view that the updating of its registration statements pursuant to Section 10(a)(3) of the Securities Act of 1933, as amended (the "Securities Act"), during the fiscal year ended December 31, 2009 would not preclude Sielox from utilizing Rule 12h-3 under the Securities Exchange Act of 1934, as amended (the "Exchange Act"), to suspend its duty to file with the Commission current and periodic reports, including its Arumal Report on Fonn 10-K for the fiscal year ended December 31,2009 (the "Fonn 10-K"), required by Section 15(d) of the Exchange Act and the rules promulgated thereunder. If the Staff grants the relief sought by this letter, Sielox intends to file a Fonn 15 pursuant to Rule 12h-3 to discontinue its reporting obligation under Section 15(d) of the Exchange Act prior to March 31,2010, the due date for the Fonn 10-K. Sielox has authorized us to make the statements set forth in this letter on its behalf. Sielox will continue to file all required periodic and current reports until it files a certification on Fonn 15. Background Sielox develops, designs and distributes a range of security solution products such as surveillance cameras, lenses, digital video recorders, high speed domes and access control systems. Sielox also develops, designs and distributes industrial vision products to observe HERRICK, FEINSTEIN LLP A, Ne,y York fimited iiCbiiii,/ partnership including New York professional corporations. 2 PARK AVENUE, NE\VYORK, NY 10016 "TEL 212.592.1400" FAX 212.592.1500" www.herrick.com HI" 5704544".3 #11571/0006