Tuesday, March 05, 2019 12:54:30 PM
As reported From the SEC telling QSEP to remove “proven” from its disclosures
” Based on the information you provided on a supplemental basis and the related disclosures, and for the reasons cited in prior comment 2, please revise your disclosure to remove the claim that the technology has been “proven.” 4. Similarly, please revise to eliminate the suggestion at page 6 that you have “proven” your “ability to build, deliver and operate [your] AOT equipment on a high-volume commercial pipeline” in light of the details you supplied regarding the problems your equipment has encountered and the lack of any substantial commercial usage. As you state at page 10, you “have not proven the commercial viability of this product.”
https://www.sec.gov/Archives/edgar/data/1103795/000000000016078381/filename1.pdf
Qsep Lawfirm agreeing to do so
“
As stated on page 10, we “have not proven the commercial viability of this product.” To get there, we need to have final proof of efficacy, demonstrate financial benefit to the oil pipeline operators, and address other risk factors related to market adoption as detailed on page 16. However, based on our experience with Kinder Morgan and other potential customers, pipeline operators appear to be comfortable with our ability to build, deliver and operate our AOT equipment.
We believe the use of the word “proven,” in the context of the disclosures and discussion above, does not suggest that the AOT technology is, at this time, commercially viable. Nonetheless, to address the staff’s concerns, we will revise future filings by removing the word “proven” and replacing it with the word “demonstrates” or “shows.” Please advise.”
https://www.sec.gov/Archives/edgar/data/1103795/000101968716006601/filename1.htm
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