Aiming to become the global leader in chip-scale photonic solutions by deploying Optical Interposer technology to enable the seamless integration of electronics and photonics for a broad range of vertical market applications

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Message: Question for Fairchij

Yesterday Green 88 posted links to correspondance between the company and the SEC regarding a NASDAQ listing. Two responses of the company caught my eye and raised some questions - hopefully you can resolve them or bring them up at the AGM (I assume you are attending).

4.To the extent that the company materially relies on governmental funding, please add a separate risk factor addressing any relevant political factors which may impact whether you continue to receive governmental funding.

Response to Comment No. 4

The Company does not anticipate any continuing governmental funding beyond the expiration of the current SBIR grant, as has been reflected throughout the Amended Registration Statement. As such, political factors relevant to governmental funding for science and technological development will not impact the Company.

Does this imply no government contract as I did not see them referenced in the reply letter?

8.Please clarify the status of your relationship with BAE and discuss its terms. If you do not own or have rights to the technology developed by or with them, please clearly state that fact and describe the risks associated with your relationship with BAE.

Response to Comment No. 8

The Company’s wholly-owned subsidiary, ODIS, Inc., has entered into a joint development agreement with BAE, a global defense, security and aerospace technology development company, as disclosed on page 61 of the original Registration Statement. Under ODIS, Inc.’s agreement with BAE, each party maintains an undivided 50% joint interest in all intellectual property developed pursuant to the terms of the agreement (subject to ODIS, Inc.’s licensing obligations to UCONN). The Company has revised the disclosure on page 12 of the Amended Registration Statement to further describe the relationship.

How does this impact (if at all) the ownership of the fully integrated opto-electic chip when it is finalized and commercialized.


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