QS Energy Inc (QSEP)

[mr_sano]

Truth be told with actual SEC correspondence:

https://www.sec.gov/Archives/edgar/data/1103795/000000000016068072/filename1.pdf


“ Page 2
2. We note your response to our prior comment 3. Please provide specific, objective support for your statement at page 3 that your AOT technology “has been proven . . . in full scale operation on a commercial crude oil pipeline to increase the energy efficiency of oil pipeline pump stations.” Alternatively, please revise or remove this language and all similar claims. In that regard, we note the following:
The AOT technology appears to lack a clear demonstration of full-field sustained commercial effectiveness.
The tests appear to be of limited duration and do not appear to clearly demonstrate the applicability and benefits of the technology under continuous long-term operating conditions.
Your deployment of AOT technology on the TransCanada Keystone pipeline and the Kinder Morgan KMCC pipeline has been limited to initial testing rather than full- scale operation with proven efficacy.
You disclose at page 14 that “our technology is commercially unproven, and the use of our technology by others is limited.”
Similarly, please provide us with specific support for your assertions at page 8 that your Joule Heat system “is much more efficient than current electric-powered heat solutions (35±% vs 80±%),” that the system “eliminates local emissions, [thus conferring] a key advantage over current natural-gas based systems,” and that it “can be made in a small enough form factor to expand the market into mobile applications such as truck and train transport systems.”
3. At an appropriate place in your filing, please disclose the particular examples you provided in response to prior comment 6 with regard to the limited use of your technology in “joint development, research, and testing applications.”