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Sputnik

09/25/20 10:00 AM

#8178 RE: Sputnik #8177


Summary of Agreements, page 7

1. We note the numerous agreements and “relationships” mentioned under Item 1 of this filing. Please revise future filings to describe in specific, concrete terms, the nature of the relationships, including the terms of any material agreements and the nature and extent of each party’s obligations. For example, it is unclear what the “recently formed relationships” require of each party, such as the nature and extent of any “collaboration,” and whether an actual, written agreement governs those obligations. Please also revise future filings to disclose what specifically has been accomplished to date pursuant to these agreements and “relationships” and what remains to be achieved, including any material obstacles that are known to exist. Ensure your disclosure distinguishes actual accomplishments from aspirations and goals.

Response
The Company acknowledges the Staff’s comment and advises the Staff that it will revise future filings to describe in specific, concrete terms, the nature of the relationships, including the terms of any material agreements and the nature and extent of each party’s obligations, as well as disclose what specifically has been accomplished to date pursuant to these agreements and “relationships” and what remains to be achieved, including any material obstacles that are known to exist.