SEC Comment Letter 0000000000-24-012394 to Nordicus Partners Corp (NORD) (CIK 0001011060) (NORD)
Nordicus Partners Corp (NORD) (CIK 0001011060)
Date: Nov. 7, 2024 · CIK: 0001011060 · Accession: 0000000000-24-012394
AI Filing Summary & Sentiment
Referenced dates: September 23, 2024
Letter
November 7, 2024 Johannes Ejnar Pitzner Director JE Pitzner Holding ApS Pilevej 4 DK-4180 Sorø Denmark Re:JE Pitzner Holding ApS Nordicus Partners Corporation Schedule 13D/A Filed by JE Pitzner Holding ApS Filed November 5, 2024 File No. 005-48655 Dear Johannes Ejnar Pitzner: We have conducted a limited review of the above-captioned filing and have the following comment . Please respond to this letter by amending the filing or by providing the requested information. If you do not believe our comment applies to your facts and circumstances or that an amendment is appropriate , please advise us why in a response letter. After reviewing any amendment to the filing and any information provided in response to this comment, we may have additional comments. Schedule 13D/A Filed November 5, 2024 General 1.We have reviewed your response to prior comment two in our letter dated September 23, 2024. We note that the revised disclosure offered in response to Item 2 of Schedule 13D indicates that "[t]he sole owner and officer of the Reporting Person is Johannes Ejnar Pitzner." Please advise us, with a view toward revised disclosure, why you, Mr. Pitzner, were not identified as a beneficial owner on the cover page within this filing or a filing made independent of this one. Refer to Rule 13d-3(a) of Regulation 13D-G, which rule provision makes clear that a beneficial owner includes any person who, directly or indirectly, through any contract, arrangement, understanding, relationship, or otherwise has or shares voting or investment power over a class of equity security specified in Rule 13d-1(i)(1).
November 7, 2024 Page 2 We remind you that the filing person is responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please direct any questions to Shane Callaghan at 202-551-6977 or Nicholas Panos at 202-551-3266. Sincerely, Division of Corporation Finance Office of Mergers & Acquisitions
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November 7, 2024
Johannes Ejnar Pitzner
Director
JE Pitzner Holding ApS
Pilevej 4
DK-4180 Sorø
Denmark
Re:JE Pitzner Holding ApS
Nordicus Partners Corporation
Schedule 13D/A Filed by JE Pitzner Holding ApS
Filed November 5, 2024
File No. 005-48655
Dear Johannes Ejnar Pitzner:
We have conducted a limited review of the above-captioned filing and have the
following comment .
Please respond to this letter by amending the filing or by providing the requested
information. If you do not believe our comment applies to your facts and circumstances or
that an amendment is appropriate , please advise us why in a response letter.
After reviewing any amendment to the filing and any information provided in
response to this comment, we may have additional comments.
Schedule 13D/A Filed November 5, 2024
General
1.We have reviewed your response to prior comment two in our letter dated September
23, 2024. We note that the revised disclosure offered in response to Item 2 of
Schedule 13D indicates that "[t]he sole owner and officer of the Reporting Person is
Johannes Ejnar Pitzner." Please advise us, with a view toward revised disclosure, why
you, Mr. Pitzner, were not identified as a beneficial owner on the cover page within
this filing or a filing made independent of this one. Refer to Rule 13d-3(a) of
Regulation 13D-G, which rule provision makes clear that a beneficial owner includes
any person who, directly or indirectly, through any contract, arrangement,
understanding, relationship, or otherwise has or shares voting or investment power
over a class of equity security specified in Rule 13d-1(i)(1).
November 7, 2024
Page 2
We remind you that the filing person is responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the
staff.
Please direct any questions to Shane Callaghan at 202-551-6977 or Nicholas Panos at
202-551-3266.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions