SEC Comment Letter for Outdoor Holding (POWW) — Sep 12, 2019
Outdoor Holding Co
Date: Sept. 12, 2019 · CIK: 0001015383 · Accession: 0000000000-19-013514
AI Filing Summary & Sentiment
File numbers found in text: 333-226087
Letter
September 12, 2019 Fred W. Wagenhals President and Chief Executive Officer Ammo, Inc. 7681 East Gray Road Scottsdale, Arizona 85260 Re:Ammo, Inc. Amendment No. 4 to Registration Statement on Form S-1 Filed August 30, 2019 File No. 333-226087 Dear Mr. Wagenhals: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our 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 comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 14, 2019 letter. Form S-1/A filed August 30, 2019 General 1.We note your response to prior comment 5. Please provide risk factor disclosure clearly describing any risks or other impacts that your forum selection provision will have on investors, including but not limited to, increased costs to bring a claim and that these provisions can discourage claims or limit investors' ability to bring a claim in a judicial forum that that they find favorable. In addition, clearly state that the provision does not apply to federal securities law claims or applies only to state law claims, as applicable.
FirstName LastNameFred W. Wagenhals Comapany NameAmmo, Inc. September 12, 2019 Page 2 FirstName LastName Fred W. Wagenhals Ammo, Inc. September 12, 2019 Page 2 You may contact Kevin Stertzel, Staff Accountant, at (202) 551-3723 or Anne McConnell, Staff Accountant, at (202) 551-3709 if you have questions regarding comments on the financial statements and related matters. Please contact Sergio Chinos, Staff Attorney, at (202) 551-7844 or Amanda Ravitz, Assistant Director, at (202) 551-3412 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing and Construction cc: Jon S. Cohen
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September 12, 2019
Fred W. Wagenhals
President and Chief Executive Officer
Ammo, Inc.
7681 East Gray Road
Scottsdale, Arizona 85260
Re:Ammo, Inc.
Amendment No. 4 to Registration Statement on Form S-1
Filed August 30, 2019
File No. 333-226087
Dear Mr. Wagenhals:
We have reviewed your amended registration statement and have the following comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our 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 comment, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our August 14, 2019 letter.
Form S-1/A filed August 30, 2019
General
1.We note your response to prior comment 5. Please provide risk factor disclosure clearly
describing any risks or other impacts that your forum selection provision will have on
investors, including but not limited to, increased costs to bring a claim and that these
provisions can discourage claims or limit investors' ability to bring a claim in a judicial
forum that that they find favorable. In addition, clearly state that the provision does not
apply to federal securities law claims or applies only to state law claims, as applicable.
FirstName LastNameFred W. Wagenhals
Comapany NameAmmo, Inc.
September 12, 2019 Page 2
FirstName LastName
Fred W. Wagenhals
Ammo, Inc.
September 12, 2019
Page 2
You may contact Kevin Stertzel, Staff Accountant, at (202) 551-3723 or Anne
McConnell, Staff Accountant, at (202) 551-3709 if you have questions regarding comments on
the financial statements and related matters. Please contact Sergio Chinos, Staff Attorney, at
(202) 551-7844 or Amanda Ravitz, Assistant Director, at (202) 551-3412 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction
cc: Jon S. Cohen