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SEC Company Response from GLOBAL TECH INDUSTRIES GROUP, INC. (GTII) (CIK 0000356590) (GTII) — Aug 5, 2021

GLOBAL TECH INDUSTRIES GROUP, INC. (GTII) (CIK 0000356590)
Date: Aug. 5, 2021 · CIK: 0000356590 · Accession: 0001493152-21-018777

AI Filing Summary & Sentiment

File numbers found in text: 333-257846

Date
Aug. 5, 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. Amendment No. 1 Registration Statement on Form S-1 Filed July 30, 2021 File No. 333-257846

Dear Sir or Madam:

Global Tech Industries Group, Inc. (the “Company”) is filing amendment number 2 (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 August 3, 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.

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.

We have added a new column disclosing the percentage ownership of each selling shareholder after the offering. We have also expanded upon the description of the marked affiliates, and any others, to describe any position, office, or other material relationship to the Company

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

August
5, 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.

    Amendment
    No. 1 Registration Statement on Form S-1

    Filed
    July 30, 2021

    File
    No. 333-257846

Dear
Sir or Madam:

Global
Tech Industries Group, Inc. (the “Company”) is filing amendment number 2 (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 August 3, 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.

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.

We
have added a new column disclosing the percentage ownership of each selling shareholder after the offering. We have also expanded upon
the description of the marked affiliates, and any others, to describe any position, office, or other material relationship to the Company

Please
direct your correspondence regarding this matter to the undersigned.

    Very
    truly yours,

    /s/
    David Reichman

    David
    Reichman