SEC Comment Letter for CBA Florida, Inc. (CIK 0001289496) — Apr 14, 2020
CBA Florida, Inc. (CIK 0001289496)
Date: April 14, 2020 · CIK: 0001289496 · Accession: 0000000000-20-003223
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File numbers found in text: 000-50746
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April 14, 2020
Anthony Snow
President and Corporate Secretary
CBA Florida, Inc.
3753 Howard Hughes Parkway, Suite 200, Office #258
Las Vegas, NV 89169
Re:CBA Florida, Inc.
Supplemental Response Letter
Filed April 9, 2020
File No. 000-50746
Dear Mr. Snow:
We have reviewed your response to our comment letter 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 business days by providing the requested
information or advise 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.
Supplemental Response Letter filed April 9, 2020
Background of the Proposed Dissolution, page 27
1.We note the response to prior comment number 1. Please expand the disclosure regarding
each party that was contacted to describe all discussions, meetings and contacts among
specific members of the board and/or management of the Company, and representatives of
such other parties.
Interests of Certain Persons in the Dissolution, page 32
2.We note the disclosure in response to prior comment number 4 that Red Oak will be paid
$250 per hour for additional work beyond 80 hours related to the dissolution. Please
disclose the estimated amount of time Red Oak expects the dissolution to require and
whether compensation for any additional work is included in the $3.0 to $3.5 million
reserve for known, ongoing expenses.
FirstName LastNameAnthony Snow
Comapany NameCBA Florida, Inc.
April 14, 2020 Page 2
FirstName LastName
Anthony Snow
CBA Florida, Inc.
April 14, 2020
Page 2
Please contact Chris Edwards at (202) 551-6761 or Celeste Murphy at (202) 551-3257
with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Kenneth A. Schlesinger