CORRESP Filing
ABUNDIA GLOBAL IMPACT GROUP, INC.
Date: July 31, 2025 · CIK: 0001156041 · Accession: 0001641172-25-021765
AI Filing Summary & Sentiment
Reasoning
Referenced dates: July 25, 2025
Letter
Houston American Energy Corp.
Travis Street, Suite 1425
Houston, Texas 77002
VIA EDGAR
July 31, 2025
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Energy and Transportation
F Street, N.E.
Washington, D.C. 20549-3561
Attention: Anuja Majmudar and Irene Barberena-Meissner
Re: Houston American Energy Corp. Draft Registration Statement on Form S-1 Filed July 11, 2025 CIK No. 0001156041
Ladies and Gentlemen:
Set forth below are the responses of Houston American Energy Corp. (the " Company ," " we ," " us ," or " our ") to comments received from the staff of the Division of Corporation Finance (the " Staff ") of the U.S. Securities and Exchange Commission (the " Commission "), by letter dated July 25, 2025, with respect to the Company's Draft Registration Statement on Form S-1, File No. 377-08202, submitted to the Commission on July 11, 2025. Concurrently with the submission of this letter, we are filing the Registration Statement on Form S-1 (" Registration Statement ").
For reference purposes, the comments contained in the Staff's letter dated July 25, 2025 are reproduced below in italics and the corresponding responses are shown below the comments. All references to page numbers and captions correspond to the Registration Statement, unless otherwise specified herein.
Draft Registration Statement on Form S-1 submitted July 11, 2025
Security Ownership of Certain Beneficial Owners and Management, page 55
1. Please revise your disclosure to identify the natural person or persons who have voting and/or investment control of the shares held by Bower Family Holdings, LLC and Abundia Financial, LLC. Refer to Item 403 of Regulation S-K and Exchange Act Rule 13d-3.
RESPONSE : The Company respectfully acknowledges the Staff's comment and has revised its disclosure on the page 55 of the Registration Statement.
Exhibits
2. We note your exhibit index indicates that you plan to file form agreements as Exhibits 4.7 and 10.16 through 10.19. Please file executed versions of these agreements and ensure that they include any schedules, as applicable, that identify the counterparties.
RESPONSE : The Company respectfully acknowledges the Staff's comment and has revised its exhibit index of the Registration Statement, and has filed executed versions of the agreements.
* * * * *
Please direct any questions that you have with respect to the foregoing, or if any additional supplemental information is required by the Staff, to Joseph E. Segilia at jsegilia@sullivanlaw.com of Sullivan & Worcester LLP.
Very
truly yours,
HOUSTON
AMERICAN ENERGY CORP.
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CORRESP
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filename1.htm
Houston
American Energy Corp.
801
Travis Street, Suite 1425
Houston,
Texas 77002
VIA
EDGAR
July
31, 2025
United
States Securities and Exchange Commission
Division
of Corporation Finance
Office
of Energy and Transportation
100
F Street, N.E.
Washington,
D.C. 20549-3561
Attention:
Anuja Majmudar and Irene Barberena-Meissner
Re:
Houston
American Energy Corp.
Draft
Registration Statement on Form S-1
Filed
July 11, 2025
CIK
No. 0001156041
Ladies
and Gentlemen:
Set
forth below are the responses of Houston American Energy Corp. (the " Company ," " we ,"
" us ," or " our ") to comments received from the staff of the Division of Corporation
Finance (the " Staff ") of the U.S. Securities and Exchange Commission (the " Commission "),
by letter dated July 25, 2025, with respect to the Company's Draft Registration Statement on Form S-1, File No. 377-08202, submitted
to the Commission on July 11, 2025. Concurrently with the submission of this letter, we are filing the Registration Statement on Form
S-1 (" Registration Statement ").
For
reference purposes, the comments contained in the Staff's letter dated July 25, 2025 are reproduced below in italics and the corresponding
responses are shown below the comments. All references to page numbers and captions correspond to the Registration
Statement, unless otherwise specified herein.
Draft
Registration Statement on Form S-1 submitted July 11, 2025
Security
Ownership of Certain Beneficial Owners and Management, page 55
1.
Please
revise your disclosure to identify the natural person or persons who have voting and/or investment control of the shares held by
Bower Family Holdings, LLC and Abundia Financial, LLC. Refer to Item 403 of Regulation S-K and Exchange Act Rule 13d-3.
RESPONSE :
The Company respectfully acknowledges the Staff's comment and has revised its disclosure on the page 55 of the Registration
Statement.
Exhibits
2.
We
note your exhibit index indicates that you plan to file form agreements as Exhibits 4.7 and 10.16 through 10.19. Please file executed
versions of these agreements and ensure that they include any schedules, as applicable, that identify the counterparties.
RESPONSE :
The Company respectfully acknowledges the Staff's comment and has revised its exhibit index of the Registration Statement,
and has filed executed versions of the agreements.
*
* * * *
Please
direct any questions that you have with respect to the foregoing, or if any additional supplemental information is required by the Staff,
to Joseph E. Segilia at jsegilia@sullivanlaw.com of Sullivan & Worcester LLP.
Very
truly yours,
HOUSTON
AMERICAN ENERGY CORP.
By:
/s/
Edward Gillespie
Name:
Edward
Gillespie
Title:
Chief
Executive Officer
Enclosures
cc:
Joseph
E. Segilia