SEC Comment Letter for GALAXY NEXT GENERATION, INC. (GAXYQ) (CIK 0001127993) — Mar 3, 2020
GALAXY NEXT GENERATION, INC. (GAXYQ) (CIK 0001127993)
Date: March 3, 2020 · CIK: 0001127993 · Accession: 0000000000-20-001916
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File numbers found in text: 333-235905
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March 2, 2020
Magen McGahee
Chief Financial Officer
Galaxy Next Generation, Inc.
286 Big A Road
Toccoa, Georgia 30577
Re:Galaxy Next Generation, Inc.
Registration Statement on Form S-1
Response filed February 18, 2020
File No. 333-235905
Dear Ms. McGahee:
We have reviewed your amended registration statement and have the following
comment. In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
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 our comment, we may have additional comments. Our reference to our
prior comment is a reference to the comment in our February 5, 2020 letter.
Response filed February 18, 2020
General
1.We note your response to prior comment 1. However, we continue to believe that the
three-month period ending June 30, 2018 does not meet the definition of a one-year period
under Rule 3-06 of Reg. S-X. To satisfy your obligation under Rule 8-02 of Reg. S-X to
file financial statements for two fiscal years, please amend this filing to include audited
financial statements for the year ended March 31, 2018 or tell us why you are not required
to do so.
FirstName LastNameMagen McGahee
Comapany NameGalaxy Next Generation, Inc.
March 2, 2020 Page 2
FirstName LastName
Magen McGahee
Galaxy Next Generation, Inc.
March 2, 2020
Page 2
Please contact Daniel Morris at (202) 551-3314 or Erin Jaskot at (202) 551-3442 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Leslie Marlow, Esq.