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
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File numbers found in text: 333-257846
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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