United States securities and exchange commission logo
March 5, 2024
Robert Berman
Chief Executive Officer
Rekor Systems, Inc.
6721 Columbia Gateway Drive, Suite 400
Columbia, MD 21046
Re: Rekor Systems, Inc.
Registration
Statement on Form S-3
Filed February 27,
2024
File No. 333-277393
Dear Robert Berman:
We have conducted a limited review of your registration statement
and have the
following comment(s).
Please respond to this letter by amending your registration
statement and providing the
requested information. If you do not believe a comment applies to your
facts and circumstances
or do not believe an amendment is appropriate, please tell us why in
your response.
After reviewing any amendment to your registration statement and
the information you
provide in response to this letter, we may have additional comments.
Registration Statement on Form S-3 Filed February 27, 2024
General
1. We note that your
company incurred net losses in fiscal years 2021 and 2022. Please
update your financial
statements and related financial information in accordance with Item
8-08(b) of Regulation
S-X. Please note that you will be required to include your audited
financial statements or
file and incorporate by reference your annual report for fiscal year
ended December 31,
2023, before we will accelerate the effective date of this registration
statement.
We remind you that the company and its management are
responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments,
action or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration.
Please allow adequate
time for us to review any amendment prior to the requested effective
date of the registration
Robert Berman
Rekor Systems, Inc.
March 5, 2024
Page 2
statement.
Please contact Eranga Dias at 202-551-8107 or Geoffrey Kruczek at
202-551-3641 with
any other questions.
Sincerely,
FirstName LastNameRobert Berman
Division of Corporation
Finance
Comapany NameRekor Systems, Inc.
Office of Manufacturing
March 5, 2024 Page 2
cc: William Bruno
FirstName LastName