SEC Comment Letter 0000000000-23-012855 to Nordicus Partners Corp (NORD) (CIK 0001011060) (NORD)
Nordicus Partners Corp (NORD) (CIK 0001011060)
Date: Nov. 27, 2023 · CIK: 0001011060 · Accession: 0000000000-23-012855
AI Filing Summary & Sentiment
File numbers found in text: 333-274588
Letter
United States securities and exchange commission logo November 27, 2023 Henrik Rouf President and Chief Executive Officer Nordicus Partners Corp 3651 Lindell Road Suite D565 Las Vegas, NV 89103 Re:Nordicus Partners Corp Amendment No. 2 to Registration Statement on Form S-1 Filed November 13, 2023 File No. 333-274588 Dear Henrik Rouf: We have reviewed your amended registration statement and have the following comments. 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 November 7, 2023 letter. Amendment No. 2 to Registration Statement on Form S-1 Cover page 1.We note your response to prior comment 1 and reissue. Your revised disclosure does not appear to state that the selling stockholders are underwriters within the meaning of Section 2(a)(11) of the Securities Act. Plan of Distribution, page 41 2.We note your response to prior comment 3 and reissue. You do not appear to have revised to make clear that the Selling Stockholders will sell at a fixed price, as your response indicates.
FirstName LastNameHenrik Rouf Comapany NameNordicus Partners Corp November 27, 2023 Page 2 FirstName LastName Henrik Rouf Nordicus Partners Corp November 27, 2023 Page 2 Notes to Unaudited Consolidated Financial Statements for the Quarterly Period Ended June 30, Note 1 - Organization and Description of Business, page F-18 3.It does not appear you revised your disclosure in the fifth paragraph of note 1 of your interim financial statements on page F-18 to conform to the same disclosure in note 1 of your annual financial statements. Please revise. Please contact Keira Nakada at 202-551-3659 or Doug Jones at 202-551-3309 if you have questions regarding comments on the financial statements and related matters. Please contact Jennie Beysolow at 202-551-8108 or Dietrich King at 202-551-8071 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Ernest M. Stern, Esq.
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United States securities and exchange commission logo
November 27, 2023
Henrik Rouf
President and Chief Executive Officer
Nordicus Partners Corp
3651 Lindell Road
Suite D565
Las Vegas, NV 89103
Re:Nordicus Partners Corp
Amendment No. 2 to Registration Statement on Form S-1
Filed November 13, 2023
File No. 333-274588
Dear Henrik Rouf:
We have reviewed your amended registration statement and have the following
comments.
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 November 7, 2023 letter.
Amendment No. 2 to Registration Statement on Form S-1
Cover page
1.We note your response to prior comment 1 and reissue. Your revised disclosure does not
appear to state that the selling stockholders are underwriters within the meaning of Section
2(a)(11) of the Securities Act.
Plan of Distribution, page 41
2.We note your response to prior comment 3 and reissue. You do not appear to have revised
to make clear that the Selling Stockholders will sell at a fixed price, as your response
indicates.
FirstName LastNameHenrik Rouf
Comapany NameNordicus Partners Corp
November 27, 2023 Page 2
FirstName LastName
Henrik Rouf
Nordicus Partners Corp
November 27, 2023
Page 2
Notes to Unaudited Consolidated Financial Statements for the Quarterly Period Ended June 30,
2023
Note 1 - Organization and Description of Business, page F-18
3.It does not appear you revised your disclosure in the fifth paragraph of note 1 of your
interim financial statements on page F-18 to conform to the same disclosure in note 1 of
your annual financial statements. Please revise.
Please contact Keira Nakada at 202-551-3659 or Doug Jones at 202-551-3309 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jennie Beysolow at 202-551-8108 or Dietrich King at 202-551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Ernest M. Stern, Esq.