SEC Comment Letter 0000000000-23-001429 to NITCHES INC (NICH) (CIK 0000772263)
NITCHES INC (NICH) (CIK 0000772263)
Date: Feb. 10, 2023 · CIK: 0000772263 · Accession: 0000000000-23-001429
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File numbers found in text: 000-13851
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<TYPE>TEXT-EXTRACT
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United States securities and exchange commission logo
February 10, 2023
John Morgan
Chief Executive Officer
Nitches Inc.
1333 N Buffalo Dr.
Suite 210
Las Vegas, NV 89128
Re: Nitches Inc.
Amendment No. 1 to
Form 10-12G
Filed January 26,
2023
File No. 000-13851
Dear John Morgan:
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.
Amendment No. 1 to Form 10-12G
Executive Compensation, page 21
1. Please update your
compensation disclosure to reflect the fiscal year ended August 31,
2022.
Item 15. Financial Statements and Exhibits
a) Financial Statements, page 26
2. Please revise to update
the financial statements and related disclosures included in your
Form 10 pursuant to
Article 8-08 of Regulation S-X.
John Morgan
FirstName
Nitches Inc.LastNameJohn Morgan
Comapany10,
February NameNitches
2023 Inc.
February
Page 2 10, 2023 Page 2
FirstName LastName
General
3. We note your responses to comments 9 and 10. Please confirm that you
have ceased all
activities/initiatives involving NFTs other than in regards to OVS.
Please also explain
your ongoing role(s) relating to the POM project and the related POM
NFTs, including
any fees that you are entitled to in connection with resales.
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 Melissa Gilmore at 202-551-3777 or Hugh West at
202-551-3872 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Alex King at 202-551-8631 or Asia Timmons-Pierce at 202-551-3754 with
any other
questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing
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