SEC Company Response from NextTrip, Inc. (NTRP) (CIK 0000788611) (NTRP) — Jun 19, 2019
NextTrip, Inc. (NTRP) (CIK 0000788611)
Date: June 19, 2019 · CIK: 0000788611 · Accession: 0001493152-19-009452
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38015
Referenced dates: June 12, 2019, May 23, 2019
Letter
TroyGould pc
Century Park East, 16th Floor
Los Angeles, California 90067-2367
Tel (310) 553-4441 | Fax (310) 201-4746
www.troygould.com
Darren Freedman ● (310) 789-1207 ● dfreedman@troygould.com File No. 03072-0001
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Office of Manufacturing and Construction
F Street, N.E.
Washington, D.C. 20549
Re: Sigma Labs, Inc.
Form 10-Q for Fiscal Quarter Ended March 31, 2019
Response Dated June 4, 2019
File No. 001-38015
Ladies and Gentlemen:
By letter dated June 12, 2019, the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) provided Sigma Labs, Inc. (the “Company”) with an additional comment after reviewing the Company’s June 4, 2019 response to the Staff’s comment letter.
This letter sets forth the Company’s response to the Staff’s comment. The numbered response and the heading set forth below correspond to the numbered comment and heading in the Staff’s letter dated June 12, 2019.
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 non-vested shares of common stock granted to the non-employee directors. It appears that the non-employee directors meet the definition of employees per ASC 718-20.
COMPANY’S RESPONSE:
Based on further research, the Company has determined that the accounting treatment previously applied to the subject grant of shares of common stock to the Company’s non-employee directors was incorrect. As the error had a $0 impact on both the cash balance and the net loss reported in the Company’s Form 10-Q, the Company has determined that it is not material to users of the Company’s financial statements. Accordingly, the Company will correct such accounting treatment immediately and the result of such correction will be reflected on the Balance Sheet included in the Company’s Form 10-Q for the quarterly period ended June 30, 2019.
Securities and Exchange Commission
June 19, 2019
Page 2
Please advise the undersigned if you desire to receive any additional information in connection with your letter dated June 12, 2019.
Very
truly yours,
TROYGOULD
PC
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CORRESP
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filename1.htm
TroyGould
pc
1801
Century Park East, 16th Floor
Los
Angeles, California 90067-2367
Tel
(310) 553-4441 | Fax (310) 201-4746
www.troygould.com
Darren
Freedman ● (310) 789-1207 ● dfreedman@troygould.com
File
No. 03072-0001
VIA
EDGAR
Securities
and Exchange Commission
Division
of Corporation Finance
Office
of Manufacturing and Construction
100
F Street, N.E.
Washington,
D.C. 20549
Re:
Sigma
Labs, Inc.
Form
10-Q for Fiscal Quarter Ended March 31, 2019
Response
Dated June 4, 2019
File
No. 001-38015
Ladies
and Gentlemen:
By
letter dated June 12, 2019, the staff (the “Staff”) of the Division of Corporation Finance of the Securities
and Exchange Commission (the “Commission”) provided Sigma Labs, Inc. (the “Company”) with
an additional comment after reviewing the Company’s June 4, 2019 response to the Staff’s comment letter.
This
letter sets forth the Company’s response to the Staff’s comment. The numbered response and the heading set forth below
correspond to the numbered comment and heading in the Staff’s letter dated June 12, 2019.
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 non-vested shares of common stock granted to the non-employee
directors. It appears that the non-employee directors meet the definition of employees per ASC 718-20.
COMPANY’S
RESPONSE:
Based
on further research, the Company has determined that the accounting treatment previously applied to the subject grant of shares
of common stock to the Company’s non-employee directors was incorrect. As the error had a $0 impact on both the cash balance
and the net loss reported in the Company’s Form 10-Q, the Company has determined that it is not material to users of the
Company’s financial statements. Accordingly, the Company will correct such accounting treatment immediately and the result
of such correction will be reflected on the Balance Sheet included in the Company’s Form 10-Q for the quarterly period ended
June 30, 2019.
Securities and Exchange Commission
June 19, 2019
Page 2
Please
advise the undersigned if you desire to receive any additional information in connection with your letter dated June 12, 2019.
Very
truly yours,
TROYGOULD
PC
/s/
Darren Freedman
Darren
Freedman