SEC Company Response from Data443 Risk Mitigation, Inc. (ATDS) (CIK 0001068689) (ATDS) — Sep 8, 2025
Data443 Risk Mitigation, Inc. (ATDS) (CIK 0001068689)
Date: Sept. 8, 2025 · CIK: 0001068689 · Accession: 0001641172-25-026903
AI Filing Summary & Sentiment
File numbers found in text: 024-12649
Referenced dates: August 26, 2025
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CORRESP
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filename1.htm
NEWLAN
LAW FIRM, PLLC
2201
Long Prairie Road, Suite 107-762
Flower
Mound, Texas 75022
September
8, 2025
Marion
Graham
Office
of Technology
Division
of Corporation Finance
Securities
and Exchange Commission
100
F Street, N.E.
Washington,
D.C. 20549
Re:
Data443
Risk Mitigation, Inc.
Offering
Statement on Form 1-A
Filed
August 12, 2025
File
No. 024-12649
Dear
Ms. Graham:
This
is in response to the letter of comment of the Staff dated August 26, 2025, relating to the captioned Offering Statement on Form 1-A
of Data443 Risk Mitigation, Inc. (the “Company”). Each of the Staff’s comments is addressed below, seriatim:
Offering
Statement on Form 1-A
Cover
Page
Comment
No. 1: Please clarify how soon after qualification you expect to hold your initial closing, how you will inform investors of the
closing(s), and whether you may terminate the offering without ever having a closing.
Please
be advised that disclosure has been added to the Cover Page, in response to such comment.
Risk
Factors, page 3
Comment
No. 2: Please add a risk factor discussing the company’s history of filing late periodic reports and the consequences of those
late filings.
Please
be advised that disclosure has been added to the third risk factor, in response to such comment.
Use
of Proceeds, page 18
Comment
No. 3: We note that you intend to use a portion of the net proceeds from this offering to repay certain debt. Describe the material
terms of such debt and, if the debt was incurred in the past year, describe the use of the proceeds arising from the debt. Please also
state whether or not the proceeds will be used to compensate or otherwise make payments to your officers or directors or any of your
subsidiaries. Refer to Instruction 6 to Part II, Item 6 of Form 1-A.
Please
be advised that disclosure has been added to the Use of Proceeds section, in response to such comment.
General
Comment
No. 4: We note that in Part I the number of securities offered is listed as 1,000,000,000 at a price of $0.0005, with the aggregate
offering price of $500,000. We also note that in Part II of the offering statement you disclose that you plan to sell 1,000,000,000 shares
with an aggregate offering price of $1,000,000. Please revise for consistency.
Please
be advised that, in furtherance of the telephone conversion with the Staff, the Dilution and Use of Proceeds sections, an assumed offering
price of $.0005 (the midpoint price of the included price range) has been included in the disclosure.
Oral
Comment No. 1: Financial statements for the period ended June 30, 2025, should be included in the filing.
Please
be advised that the Company’s financial information, that is the financial statements and related Management’s Discussion
and Analysis section, for the period ended June 30, 2025, has been included in the amendment.
_________________________________
Please
be further advised that, in light of recent discussions between the Staff and the undersigned, the Company confirms that it understands
each of the provisions of Rule 253(b), including the notes to such paragraph.
_________________________________
We
believe that this filing is now in order for qualification.
Please
feel free to contact the undersigned at (940) 367-6154, should you have any questions regarding this letter or the Amendment.
Thank
you for your attention in this matter.
Sincerely,
NEWLAN
LAW FIRM, PLLC
By:
/s/
Eric Newlan
Eric
Newlan
Managing
Member
cc:
Data443 Risk Mitigation, Inc.