Correspondence 0001079973-22-001419 from NUGL, INC. (NUGL) (CIK 0001096768)
NUGL, INC. (NUGL) (CIK 0001096768)
Date: Nov. 10, 2022 · CIK: 0001096768 · Accession: 0001079973-22-001419
AI Filing Summary & Sentiment
File numbers found in text: 024-11581
Letter
Correspondence
Kaya Group / NUGL Inc.
OTC: NUGL
November 10, 2022
Securities and Exchange Commission
Division of Corporation Finance
Office of Trade & Services
F Street N.E.
Washington, D.C. 20549
Re: NUGL, INC. (the “Company”)
Post-Qualification Amendment No. 4 to Offering Statement 1-A
Filed September 22, 2021 (as amended)
File No. 024-11581
Attention: Division of Corporate Finance:
We respectfully request that the Commission qualify the Post-Qualification Amendment No. 4 to Offering Statement on Form 1-A on or before 2pm EST, Monday November 14, 2022, or as soon as practicable. On behalf of the Company, the undersigned: (i) confirms that at least one state has advised the Company that it is prepared to qualify the offering, and (ii) on behalf of the Company, the undersigned acknowledges that:
1. Should the Commission or the Staff, acting pursuant to delegated authority, declare the filing of the Offering Statement qualified, it does not foreclose the Commission from taking any action with respect to the filing;
2. The action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing qualified, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
3. We do not require FINRA to approve any of our compensation agreements, as we are self-underwriting and not engaging any third parties to assist in the sale or marketing of this Offering. Note, the management fee that the Company receives upon the sale of any real estate does not require us to register as a broker/dealer or an investment adviser under the 1940 Act or any other applicable state statute; and
4. The Company may not assert Staff comments and the declaration of qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
If you have any questions or comments regarding the foregoing, please do not hesitate to contact me at 714-383-9982.
Sincerely, NUGL, INC.
/s/ Balram Vaswani
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filename1.htm
Correspondence
Kaya Group / NUGL Inc.
OTC:
NUGL
November
10, 2022
Securities
and Exchange Commission
Division
of Corporation Finance
Office
of Trade & Services
100
F Street N.E.
Washington,
D.C. 20549
Re: NUGL, INC. (the “Company”)
Post-Qualification Amendment No. 4 to Offering Statement 1-A
Filed September
22, 2021 (as amended)
File No. 024-11581
Attention: Division of Corporate Finance:
We respectfully
request that the Commission qualify the Post-Qualification Amendment No. 4 to Offering Statement on Form 1-A on or before 2pm EST, Monday
November 14, 2022, or as soon as practicable. On behalf of the Company, the undersigned: (i) confirms that at least one state has advised
the Company that it is prepared to qualify the offering, and (ii) on behalf of the Company, the undersigned acknowledges that:
1. Should
the Commission or the Staff, acting pursuant to delegated authority, declare the filing of the Offering Statement qualified, it does not
foreclose the Commission from taking any action with respect to the filing;
2. The
action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing qualified, does not relieve the
Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
3. We
do not require FINRA to approve any of our compensation agreements, as we are self-underwriting and not engaging any third parties to
assist in the sale or marketing of this Offering. Note, the management fee that the Company receives upon the sale of any real estate
does not require us to register as a broker/dealer or an investment adviser under the 1940 Act or any other applicable state statute;
and
4. The
Company may not assert Staff comments and the declaration of qualification as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.
If you have any questions or comments
regarding the foregoing, please do not hesitate to contact me at 714-383-9982.
Sincerely, NUGL, INC.
/s/ Balram Vaswani
Name: Balram Vaswani
Title: Chief Executive Officer