SEC Comment Letter for CordovaCann Corp. (LVRLF) (CIK 0001168981) (LVRLF) — Jan 20, 2016
CordovaCann Corp. (LVRLF) (CIK 0001168981)
Date: Jan. 20, 2016 · CIK: 0001168981 · Accession: 0000000000-16-061983
AI Filing Summary & Sentiment
File numbers found in text: 000-50492
Letter
Mail Stop 3561 January 20, 2016 Ashish Kapoor Chief Financial Officer LiveReel Media Corporation 70 York Street, Suite 1610 Toronto, Ontario M5J 1S9, Canada
Re: LiveReel Media Corporation Form 20-F for the Fiscal Year Ended June 30, 2015 Filed October 29, 2015 File No. 000-50492
Dear Mr. Kapoor :
We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Financial Statements
1. We note you present only two years of audited financial statements. Item 8.A.2 of Form 20-F requires comparative financial statements that cover the latest three financial years. Please amend your filing to include audited financial statements prepared in accordance with IFRS for each of the three latest financial years and to obtain a revised audit report from your auditor which covers the three years presented to comply with Item 8.A.2 or tell us why you believe this guidance does n ot apply to you. To the extent that you provide audited financial statements for all three years, please revise Management´s Discussion and Analysis accordingly.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Ashish Kapoor LiveReel Media Corporation January 20, 2016 Page 2
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the di sclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact Melissa Gilmore at (202) 551 -3777 or me at (202) 551 -3379 with any questions.
Sincerely,
/s/ Melissa Raminpour
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Mail Stop 3561 January 20, 2016 Ashish Kapoor Chief Financial Officer LiveReel Media Corporation 70 York Street, Suite 1610 Toronto, Ontario M5J 1S9, Canada Re: LiveReel Media Corporation Form 20-F for the Fiscal Year Ended June 30, 2015 Filed October 29, 2015 File No. 000-50492 Dear Mr. Kapoor : We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Financial Statements 1. We note you present only two years of audited financial statements. Item 8.A.2 of Form 20-F requires comparative financial statements that cover the latest three financial years. Please amend your filing to include audited financial statements prepared in accordance with IFRS for each of the three latest financial years and to obtain a revised audit report from your auditor which covers the three years presented to comply with Item 8.A.2 or tell us why you believe this guidance does n ot apply to you. To the extent that you provide audited financial statements for all three years, please revise Management´s Discussion and Analysis accordingly. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. Ashish Kapoor LiveReel Media Corporation January 20, 2016 Page 2 In responding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the di sclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. You may contact Melissa Gilmore at (202) 551 -3777 or me at (202) 551 -3379 with any questions. Sincerely, /s/ Melissa Raminpour Melissa Raminpour Branch Chief Office of Transportation and Leisure