SEC Comment Letter for Red Cat Holdings, Inc. (RCAT) (CIK 0000748268) (RCAT) — Jun 26, 2019
Red Cat Holdings, Inc. (RCAT) (CIK 0000748268)
Date: June 26, 2019 · CIK: 0000748268 · Accession: 0000000000-19-010337
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File numbers found in text: 000-31587
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June 25, 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 Schedule 14C
Filed May 24, 2019
File No. 000-31587
Dear Mr. Thompson:
We have reviewed your June 13, 2019 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to the comment in
our June 7, 2019 letter.
Preliminary Information Statement on Schedule 14C
General
1.We note your response to our prior comment regarding the applicability of Note A of
Schedule 14A. Please revise to provide a description of the business acquired and limited
financial information, including revenues, net income (loss), assets, and liabilities.
FirstName LastNameJeffrey Thompson
Comapany NameTimefireVR, Inc.
June 25, 2019 Page 2
FirstName LastName
Jeffrey Thompson
TimefireVR, Inc.
June 25, 2019
Page 2
You may contact Matthew Derby, Staff Attorney, at (202) 551-3334 or Edwin Kim,
Attorney-Advisor, at (202) 551-3297 with any questions.
Sincerely,
Division of Corporation Finance
Office of Information Technologies
and Services
cc: Joe Lexague, Esq.