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SEC Company Response from GLOBAL TECH INDUSTRIES GROUP, INC. (GTII) (CIK 0000356590) (GTII) — Jul 30, 2021

GLOBAL TECH INDUSTRIES GROUP, INC. (GTII) (CIK 0000356590)
Date: July 30, 2021 · CIK: 0000356590 · Accession: 0001493152-21-018140

AI Filing Summary & Sentiment

File numbers found in text: 333-257846

Date
July 30, 2021
Author
David Reichman
Form
CORRESP
Company
GLOBAL TECH INDUSTRIES GROUP, INC. (GTII) (CIK 0000356590)

Letter

Via Edgar Division of Corporation Finance Attention: Donald Field Re: Global Tech Industries Group, Inc. Registration Statement on Form S-1 Filed July 12, 2021 File No. 333-257846

Dear Sir or Madam:

Global Tech Industries Group, Inc. (the “Company”) is filing amendment number 1 (the “Amendment”) to the Registration Statement on Form S-1 (the “Registration Statement”) in response to your recent review letter addressed to David Reichman, Chief Executive Officer of the Company, dated July 26, 2021 (the “SEC Letter”). This response letter, along with the amended Offering Statement, addresses the concerns you have expressed. The following numbered responses correspond to the comment numbers in the SEC Letter.

Registration Statement on Form S-1

General

1. We note that the prospectus does not contain a description of the company’s business. Please revise to include a business section and the information required by Item 101 of Regulation S-K. Refer to Item 11(a) of Form S-1.

We have added a Business section to the Registration Statement.

2. We note that the prospectus does not contain a selling security holder section. Please revise to include a selling security holder section and the information required by Item 507 of Regulation S-K. Refer to Item 7 of Form S-1. In this regard, we note that the inclusion of certain information in Exhibit 99.1 does not satisfy the form requirements of Item 7 of Form S-1.

We have removed Exhibit 99.1 and added the pertinent information from it, along with all remaining information required by Item 507 of Regulation S-K, to the Registration Statement.

3. We note that this registration statement registers a resale offering on a delayed or continuous basis pursuant to Rule 415 of the Securities Act of 1933. We also note, per Exhibit 99.1, that you are registering certain shares owned by the company in this resale offering. Please amend your disclosure to remove the company’s shares from your resale offering, as the company is ineligible to be a selling security holder in an at the market offering per Rule 415(a)(1)(i) of the Securities Act. Alternatively, please amend your filing to clearly disclose that the company is also registering a primary offering, and make conforming changes throughout your filing. If you intend to register the primary offering, please advise regarding your basis for determining that the company’s primary offering is eligible to be conducted at the market under Rules 415(a)(1) and 415(a)(4) of the Securities Act, or fix a price for your primary offering.

The shares labeled “GLOBAL TECH INDUSTRIES GROUP” inadvertently left out the full name, which includes “PROFIT SHARING PLAN.” The related shares are not being registered for a primary offering. The offering is merely a resale offering. The name of the shareholder has been corrected in the Registration Statement.

Please direct your correspondence regarding this matter to the undersigned.

Very
truly yours,
/s/
David Reichman

Show Raw Text
CORRESP
1
filename1.htm

    GLOBAL
    TECH INDUSTRIES GROUP, INC.

    511
    Sixth Avenue,

                                                                                        Suite 800

    New
York, NY 10011

July
30, 2021

Via
Edgar

United
State Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
DC 20549

    Attention:
    Donald
    Field

    Katherine
    Bagley

    Re:

    Re:
    Global Tech Industries Group, Inc.

    Registration
    Statement on Form S-1

    Filed
    July 12, 2021

    File
    No. 333-257846

Dear
Sir or Madam:

Global
Tech Industries Group, Inc. (the “Company”) is filing amendment number 1 (the “Amendment”) to the Registration
Statement on Form S-1 (the “Registration Statement”) in response to your recent review letter addressed to David Reichman,
Chief Executive Officer of the Company, dated July 26, 2021 (the “SEC Letter”). This response letter, along with the amended
Offering Statement, addresses the concerns you have expressed. The following numbered responses correspond to the comment numbers in
the SEC Letter.

Registration
Statement on Form S-1

General

1.
We note that the prospectus does not contain a description of the company’s business. Please revise to include a business section
and the information required by Item 101 of Regulation S-K. Refer to Item 11(a) of Form S-1.

We
have added a Business section to the Registration Statement.

2.
We note that the prospectus does not contain a selling security holder section. Please revise to include a selling security holder section
and the information required by Item 507 of Regulation S-K. Refer to Item 7 of Form S-1. In this regard, we note that the inclusion of
certain information in Exhibit 99.1 does not satisfy the form requirements of Item 7 of Form S-1.

We
have removed Exhibit 99.1 and added the pertinent information from it, along with all remaining information required by Item 507 of Regulation
S-K, to the Registration Statement.

3.
We note that this registration statement registers a resale offering on a delayed or continuous basis pursuant to Rule 415 of the Securities
Act of 1933. We also note, per Exhibit 99.1, that you are registering certain shares owned by the company in this resale offering. Please
amend your disclosure to remove the company’s shares from your resale offering, as the company is ineligible to be a selling security
holder in an at the market offering per Rule 415(a)(1)(i) of the Securities Act. Alternatively, please amend your filing to clearly disclose
that the company is also registering a primary offering, and make conforming changes throughout your filing. If you intend to register
the primary offering, please advise regarding your basis for determining that the company’s primary offering is eligible to be
conducted at the market under Rules 415(a)(1) and 415(a)(4) of the Securities Act, or fix a price for your primary offering.

The
shares labeled “GLOBAL TECH INDUSTRIES GROUP” inadvertently left out the full name, which includes “PROFIT SHARING
PLAN.” The related shares are not being registered for a primary offering. The offering is merely a resale offering. The name of
the shareholder has been corrected in the Registration Statement.

Please
direct your correspondence regarding this matter to the undersigned.

    Very
    truly yours,

    /s/
    David Reichman

    David
    Reichman