SEC Comment Letter for NextPlat Corp (NXPL) (CIK 0001058307) (NXPL) — Jan 30, 2015
NextPlat Corp (NXPL) (CIK 0001058307)
Date: Jan. 30, 2015 · CIK: 0001058307 · Accession: 0000000000-15-005558
AI Filing Summary & Sentiment
Reasoning
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE January 30, 201 5 Via E -mail David Rector Chief Executive Officer Orbital Tracking Corp . 1990 N. California Boulevard, 8th Floor Walnut Creek, California 94596
Re: Orbital Tracking Corp . Amendment No. 1 to Current Report on Form 8-K Filed January 21, 2015 File No. 0-25097
Dear M r. Rector :
We have reviewed your amended filing an d have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter by amending your filing and providing the requested information . If you do not believe our comments apply 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 filing and the information you provide in response to these comments, we may have additional comments.
Description of Current Business, page 3
1. Please disclose the nature of your sources for the products you currently sell through your Amazon storefront.
2. Please tell us of any relationship preexisting the license agreement between the company and Global Telesat Group or their affiliates.
3. We n ote your response to our comment 3. Please revise to clarify how you intend to develop your own satellite tracking products, especially in light of your risk factor disclosure describing product development as a long, expensive process.
Risk Factors, page 6
David Rector Great West Resources, Inc. January 30 , 201 5 Page 2
We may pursue strategic transactions in the future . . . , page 7
4. We note your response to our prior comment 8. Please tell us in your response why you believe that there is a material risk that you may engage in a transaction that would signific antly change your business profile, particularly in light of the company’s history of significant and frequent changes of business profile.
You may contact Inessa Kessman , Staff Accountant, at (202) 5 51-3371 or Ivette Leon, Assistant Chief Accountant , at (202) 551 -3351 if you have questions relating to the financial statements. Please contact Gregory Dundas , Attorney -Advisor, at (202) 551 -3436 , Celeste M. Murphy , Legal Branch Chief, at (202) 551 -3257, or me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Celeste M. Murphy for
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
January 30, 201 5
Via E -mail
David Rector
Chief Executive Officer
Orbital Tracking Corp .
1990 N. California Boulevard, 8th Floor
Walnut Creek, California 94596
Re: Orbital Tracking Corp .
Amendment No. 1 to Current Report on Form 8-K
Filed January 21, 2015
File No. 0-25097
Dear M r. Rector :
We have reviewed your amended filing an d have the following comments. In some
of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter by amending your filing and providing the requested
information . If you do not believe our comments apply 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 filing and the information you provide in
response to these comments, we may have additional comments.
Description of Current Business, page 3
1. Please disclose the nature of your sources for the products you currently sell through
your Amazon storefront.
2. Please tell us of any relationship preexisting the license agreement between the
company and Global Telesat Group or their affiliates.
3. We n ote your response to our comment 3. Please revise to clarify how you intend to
develop your own satellite tracking products, especially in light of your risk factor
disclosure describing product development as a long, expensive process.
Risk Factors, page 6
David Rector
Great West Resources, Inc.
January 30 , 201 5
Page 2
We may pursue strategic transactions in the future . . . , page 7
4. We note your response to our prior comment 8. Please tell us in your response why
you believe that there is a material risk that you may engage in a transaction that
would signific antly change your business profile, particularly in light of the
company’s history of significant and frequent changes of business profile.
You may contact Inessa Kessman , Staff Accountant, at (202) 5 51-3371 or Ivette
Leon, Assistant Chief Accountant , at (202) 551 -3351 if you have questions relating to the
financial statements. Please contact Gregory Dundas , Attorney -Advisor, at (202) 551 -3436 ,
Celeste M. Murphy , Legal Branch Chief, at (202) 551 -3257, or me at (202) 551 -3810 with
any other questions.
Sincerely,
/s/ Celeste M. Murphy for
Larry Spirgel
Assistant Director