SEC Comment Letter for Red Cat Holdings, Inc. (RCAT) (CIK 0000748268) (RCAT) — May 31, 2019
Red Cat Holdings, Inc. (RCAT) (CIK 0000748268)
Date: May 31, 2019 · CIK: 0000748268 · Accession: 0000000000-19-009222
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-31587
Letter
May 31, 2019 Jeffrey Thompson Chief Executive Officer TimefireVR, Inc. 1607 Ponce de Leon Ave, Suite 407 San Juan, PR 00909 Re:TimefireVR, Inc. Preliminary Information Statment on PRE 14C Filed May 24, 2019 File No. 000-31587 Dear Mr. Thompson: We have reviewed your filing 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 these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Preliminary Information Statement General 1.It appears that the reverse stock split and name change proposals are necessary for you to complete your Share Exchange Agreement with Red Cat Propware, Inc. Please revise your information statement to provide all of the information required by Item 14 of Schedule 14A including, if applicable, Item 11 and Item 13. Alternatively, tell us why you believe you are not required to provide some or all of this information in accordance with Note A of Schedule 14A.
FirstName LastNameJeffrey Thompson Comapany NameTimefireVR, Inc. May 31, 2019 Page 2 FirstName LastName Jeffrey Thompson TimefireVR, Inc. May 31, 2019 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Matthew Derby, Staff Attorney, at (202) 551-3334 or Edwin Kim, Attorney-Advisor, at (202) 551-3297 with any other questions. Sincerely, Division of Corporation Finance Office of Information Technologies and Services cc: Joe Lexague, Esq.
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May 31, 2019
Jeffrey Thompson
Chief Executive Officer
TimefireVR, Inc.
1607 Ponce de Leon Ave, Suite 407
San Juan, PR 00909
Re:TimefireVR, Inc.
Preliminary Information Statment on PRE 14C
Filed May 24, 2019
File No. 000-31587
Dear Mr. Thompson:
We have reviewed your filing 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Preliminary Information Statement
General
1.It appears that the reverse stock split and name change proposals are necessary for you to
complete your Share Exchange Agreement with Red Cat Propware, Inc. Please revise
your information statement to provide all of the information required by Item 14 of
Schedule 14A including, if applicable, Item 11 and Item 13. Alternatively, tell us why
you believe you are not required to provide some or all of this information in accordance
with Note A of Schedule 14A.
FirstName LastNameJeffrey Thompson
Comapany NameTimefireVR, Inc.
May 31, 2019 Page 2
FirstName LastName
Jeffrey Thompson
TimefireVR, Inc.
May 31, 2019
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact Matthew Derby, Staff Attorney, at (202) 551-3334 or Edwin Kim,
Attorney-Advisor, at (202) 551-3297 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Information Technologies
and Services
cc: Joe Lexague, Esq.