SEC Comment Letter 0000000000-25-001874 to Sentinel Holdings Ltd. (SNTL)
Sentinel Holdings Ltd.
Date: Feb. 18, 2025 · CIK: 0000889353 · Accession: 0000000000-25-001874
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-282424
Letter
February 18, 2025 Kip Eardley President James Maritime Holdings Inc. 9160 South 300 West, #101 Sandy, UT 84070 Re:James Maritime Holdings Inc. Amendment No. 3 to Registration Statement on Form S-1 Filed February 12, 2025 File No. 333-282424 Dear Kip Eardley: We have reviewed your amended registration statement and have the following comment(s). Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our January 7, 2025 letter. Amendment No. 3 to Registration Statement on Form S-1 General 1.We note your response to prior comment 3, and reissue in part. We note your auditor consent from Bush & Associates now refers to an auditor report dated February 11, 2025, whereas the auditor report from Bush & Associates included in the registration statement is dated June 3, 2024. Please revise accordingly and refile. The consent should refer to the auditor report included in the registration statement. Please revise your disclosure throughout your registration statement where appropriate, including but not limited to your "Our Business" and Management's Discussion and Analysis sections, to provide a current description of your business and reflect the current state of your business operations, activities and product lines as 2.
February 18, 2025 Page 2 applicable. Specifically, revise to reflect the status of your sales of personal protective equipment under the Gladiator business. We note that it appears you stopped selling these products in mid-2023. Please contact Kate Beukenkamp at 202-551-3861 or Dietrich King at 202-551-8071 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc:Jared Febbroriello
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February 18, 2025
Kip Eardley
President
James Maritime Holdings Inc.
9160 South 300 West, #101
Sandy, UT 84070
Re:James Maritime Holdings Inc.
Amendment No. 3 to Registration Statement on Form S-1
Filed February 12, 2025
File No. 333-282424
Dear Kip Eardley:
We have reviewed your amended registration statement and have the following
comment(s).
Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our January 7, 2025 letter.
Amendment No. 3 to Registration Statement on Form S-1
General
1.We note your response to prior comment 3, and reissue in part. We note your auditor
consent from Bush & Associates now refers to an auditor report dated February 11,
2025, whereas the auditor report from Bush & Associates included in the registration
statement is dated June 3, 2024. Please revise accordingly and refile. The consent
should refer to the auditor report included in the registration statement.
Please revise your disclosure throughout your registration statement where
appropriate, including but not limited to your "Our Business" and Management's
Discussion and Analysis sections, to provide a current description of your business
and reflect the current state of your business operations, activities and product lines as
2.
February 18, 2025
Page 2
applicable. Specifically, revise to reflect the status of your sales of personal protective
equipment under the Gladiator business. We note that it appears you stopped selling
these products in mid-2023.
Please contact Kate Beukenkamp at 202-551-3861 or Dietrich King at 202-551-8071
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Jared Febbroriello