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UPLOAD Filing

SPECTRAL CAPITAL Corp
Date: May 8, 2025 · CIK: 0001131903 · Accession: 0000000000-25-004936

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File numbers found in text: 000-50274

Date
May 8, 2025
Author
Division of
Form
UPLOAD
Company
SPECTRAL CAPITAL Corp

Letter

Re: Spectral Capital Corporation Form 8-K filed May 7, 2025 File No. 000-50274 Dear Jenifer Osterwalder:

May 8, 2025

Jenifer Osterwalder Chief Executive Officer & President Spectral Capital Corporation 701 Fifth Avenue Suite 4200 Seattle, WA 98104

We have reviewed your filing and have the following comment.

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Item 4.02 Form 8-K filed on May 7, 2025 General

1. With regard to the Item 4.02 of Form 8-K disclosures, you state the information set forth in the "third, fourth, fifth and sixth paragraphs of Item 4.01 is incorporated by reference." Please explain what disclosures you are referring to as the Item 4.01 Form 8-K disclosures include only four paragraphs and the third and fourth paragraphs do not appear to address any Item 4.02 requirements. In addition, it is unclear if the audit committee, or board of directors in the absence of an audit committee, or authorized officers discussed the matters with MG&A. Please revise and ensure you address all of the disclosures required by Item 4.02(b) of Form 8-K. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. May 8, 2025 Page 2

Please contact Kathleen Collins at (202) 551-3499 if you have questions.

Sincerely,
Division of
Corporation Finance
Office of Technology

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
 May 8, 2025

Jenifer Osterwalder
Chief Executive Officer & President
Spectral Capital Corporation
701 Fifth Avenue
Suite 4200
Seattle, WA 98104

 Re: Spectral Capital Corporation
 Form 8-K filed May 7, 2025
 File No. 000-50274
Dear Jenifer Osterwalder:

 We have reviewed your filing and have the following comment.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe
our comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Item 4.02 Form 8-K filed on May 7, 2025
General

1. With regard to the Item 4.02 of Form 8-K disclosures, you state the
information set
 forth in the "third, fourth, fifth and sixth paragraphs of Item 4.01 is
incorporated by
 reference." Please explain what disclosures you are referring to as the
Item 4.01 Form
 8-K disclosures include only four paragraphs and the third and fourth
paragraphs do
 not appear to address any Item 4.02 requirements. In addition, it is
unclear if the audit
 committee, or board of directors in the absence of an audit committee,
or authorized
 officers discussed the matters with MG&A. Please revise and ensure you
address all
 of the disclosures required by Item 4.02(b) of Form 8-K.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.
 May 8, 2025
Page 2

 Please contact Kathleen Collins at (202) 551-3499 if you have questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
</TEXT>
</DOCUMENT>