Mr. Andrew Mew
Senior Assistant Chief Accountant
Office of Transportation and Leisure
Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549
Saker Aviation Services, Inc.
Form 10-K for the Year Ended December 31, 2015
Filed April 11, 2016
Form 10-Q for the Quarterly Period Ended March 31, 2016
Filed May 16, 2016
Form 10-Q for the Quarterly Period Ended June 30, 2016
Filed August 15, 2016
File No. 000-52593
Dear Mr. Mew,
This letter is in response to the Staff’s comments received around August 25, 2016.
Forms 10-Q for Quarters Ended March 31, 2016 and June 30, 2016
Exhibits 31.1 and 31.2 Certifications
1. Please revise the introduction to paragraph (4) to read as follows: â€œThe registrantâ€™s otherÂ certifying officer and I are responsible for establishing and maintaining disclosure controlsÂ and procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internalÂ control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-
15(f)) for the registrant and haveâ€¦â€. In addition, please insert as paragraph 4(b) theÂ required language pertaining to your designing such internal control over financialÂ reportingâ€¦for external purposes in accordance with generally accepted accountingÂ principles.â€ Reference is made to the entirety of paragraph 4 of Item 601(b)(31) ofÂ Regulation S-K. The quarterly reports should be amended to include in full, the interimÂ financial statements under Item 1 and the controls and procedures section under Item 4 ofÂ the Form 10-Q. Please refer to analogous guidance in the Staffâ€™s Compliance and
Disclosure Interpretations (C&DIâ€™s), Question No. 246.13 of Regulation S-K.
RESPONSE: Future filings will contain the indicated disclosures.
2. Your letter requested that we provide a written statement from the company acknowledgingÂ that:
We look forward to any additional questions you may have as a result of our responses to your
Please contact me with any questions upon your review.
/s/ Ronald J. Ricciardi
Ronald J. Ricciardi