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SEC Comment Letter for NextTrip, Inc. (NTRP) (CIK 0000788611) (NTRP) — Jun 12, 2019

NextTrip, Inc. (NTRP) (CIK 0000788611)
Date: June 12, 2019 · CIK: 0000788611 · Accession: 0000000000-19-009798

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File numbers found in text: 001-38015

Referenced dates: May 23, 2019

Date
June 12, 2019
Author
Not clearly detected
Form
UPLOAD
Company
NextTrip, Inc. (NTRP) (CIK 0000788611)

Letter

June 12, 2019 John Rice Chief Executive Officer Sigma Labs, Inc. 3900 Paseo del Sol Santa Fe, New Mexico 87507 Re:Sigma Labs, Inc. Form 10-K for Fiscal Year Ended December 31, 2018 Response Dated June 4, 2019 Form 10-Q for Fiscal Quarter Ended March 31, 2019 Response Dated June 4, 2019 File No. 001-38015 Dear Mr. Rice: We have reviewed your June 4, 2019 response to our comment letter and have the following comment. 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. Form 10-Q for the quarterly period ended March 31, 2019 NOTE 4 - Stockholders' Equity Deferred Compensation, page 9 1.We note your response to comment 3 in our letter dated May 23, 2019. Please tell us the specific reference within ASC 718 that supports the recognition of the $225,000 prepaid asset for the nonvested shares of common stock granted to the non-employee directors. It appears that the non-employee directors meet the definition of employees per ASC 718- 10-20.

FirstName LastNameJohn Rice Comapany NameSigma Labs, Inc. June 12, 2019 Page 2 FirstName LastName John Rice Sigma Labs, Inc. June 12, 2019 Page 2 You may contact Jenn Do, Staff Accountant, at (202) 551-3743 or Tracey Houser, Staff Accountant, at (202) 551-3736 if you have questions regarding comments on the financial statements and related matters. Please contact Sergio Chinos, Staff Attorney, at (202) 551- 7844 or Frank Pigott, Staff Attorney, at (202) 551-3570 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing and Construction cc: Darren Freedman

Show Raw Text
June 12, 2019
John Rice
Chief Executive Officer
Sigma Labs, Inc.
3900 Paseo del Sol
Santa Fe, New Mexico 87507
Re:Sigma Labs, Inc.
Form 10-K for Fiscal Year Ended December 31, 2018
Response Dated June 4, 2019
Form 10-Q for Fiscal Quarter Ended March 31, 2019
Response Dated June 4, 2019
File No. 001-38015
Dear Mr. Rice:
            We have reviewed your June 4, 2019 response to our comment letter and have the
following comment.
            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.
Form 10-Q for the quarterly period ended March 31, 2019
NOTE 4 - Stockholders' Equity
Deferred Compensation, page 9
1.We note your response to comment 3 in our letter dated May 23, 2019. Please tell us the
specific reference within ASC 718 that supports the recognition of the $225,000 prepaid
asset for the nonvested shares of common stock granted to the non-employee directors. It
appears that the non-employee directors meet the definition of employees per ASC 718-
10-20.

 FirstName LastNameJohn Rice
 Comapany NameSigma Labs, Inc.
 June 12, 2019 Page 2
 FirstName LastName
John Rice
Sigma Labs, Inc.
June 12, 2019
Page 2
            You may contact Jenn Do, Staff Accountant, at (202) 551-3743 or Tracey Houser, Staff
Accountant, at (202) 551-3736 if you have questions regarding comments on the financial
statements and related matters.  Please contact Sergio Chinos, Staff Attorney, at (202) 551-
7844 or Frank Pigott, Staff Attorney, at (202) 551-3570 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction
cc:       Darren Freedman