JEFFREY G. KLEIN, P.A.
301 Yamato Road Suite 1240
Boca Raton, Florida 33431
Telephone: (561)953-1126 | Telefax: (561)994-6693 |
| Email: jklein@jkleinlegal.com |
March 24, 2015
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D. C. 20549
Attention: Ruairi Regan
Re:
Mindesta Inc.
Amendment No. 3 to Current Report on Form 8-K
Filed February 18, 2015
File No. 000-30651
Dear Sir/Madam:
The following responses are filed in connection with the Commission’s comment letter dated March 3, 2015.
1.
With respect to comment No. 1, we have expanded our disclosure under Item 2.01 to include the entirety of the disclosure as required.
2.
With respect to comment No. 2, we have deleted all costs and statistical references that we have not provided corresponding references. Any referenced reports were previously provided.
3.
With respect to comment No. 3, we have deleted the reference to Phyto Plant Research and ODF Technologies.
4.
With respect to comment No. 4, we have modified our disclosure under the both the manufacturing and operational sections to more clearly indicate that the Company expects to rely on third party manufacturers for at least the next two years.
5.
With respect to comment No. 5, we have deleted the reference that Germany and the Netherlands will be our primary market.
Sincerely,
/s/Jeffrey G. Klein
Jeffrey G. Klein, counsel
MINDESTA, INC.
(Stationary)
March 24, 2015
Securities and Exchange Commission
Washington, D.C.
Re:
Mindesta, Inc.
Amendment No. 3 to Current Report on Form 8-K
Filed February 18, 2015
File No. 000-30651
Dear Sir/Madam:
The following is filed in connection with the comment letter dated March 3, 2015.
The undersigned, on behalf of MINDESTA, INC. acknowledges that:
·
The Company is responsible for the adequacy and accuracy of the disclosure in the filing.
·
Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and
·
The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Sincerely,
/s/ Pankaj Modi
Pankaj Modi, Chief Executive Officer