SEC Comment Letter for GLOBAL TECH INDUSTRIES GROUP, INC. (GTII) (CIK 0000356590) (GTII) — Aug 3, 2021
GLOBAL TECH INDUSTRIES GROUP, INC. (GTII) (CIK 0000356590)
Date: Aug. 3, 2021 · CIK: 0000356590 · Accession: 0000000000-21-009506
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File numbers found in text: 333-257846
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United States securities and exchange commission logo
August 3, 2021
David Reichman
Chief Executive Officer
Global Tech Industries Group, Inc.
511 Sixth Avenue, Suite 800
New York, NY 10011
Re:Global Tech Industries Group, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed July 30, 2021
File No. 333-257846
Dear Mr. Reichman:
We have reviewed your amended registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our July 26, 2021 letter.
Amendment No. 1 to Registration Statement on Form S-1
The Selling Shareholders, page 15
1.We note your response to our prior comment 2 and reissue in part. Please revise to add a
new column to the selling shareholder chart to disclose the percentage (if greater than one
percent) of your common stock owned by any selling shareholder after the completion of
the offering. Additionally, please revise to indicate the nature of any position, office, or
other material relationship which any selling shareholder has had within the past three
years with the company or any of its predecessors or affiliates. In this regard, we note that
it appears that all of your current officers and directors are participating in the offering.
Refer to Item 507 of Regulation S-K.
FirstName LastNameDavid Reichman
Comapany NameGlobal Tech Industries Group, Inc.
August 3, 2021 Page 2
FirstName LastName
David Reichman
Global Tech Industries Group, Inc.
August 3, 2021
Page 2
Please contact Donald Field at 202-551-3680 or Katherine Bagley at 202-551-2545 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services