SEC Comment Letter for HYB Holding Corp. (CIK 0001307624) — Apr 27, 2020
HYB Holding Corp. (CIK 0001307624)
Date: April 27, 2020 · CIK: 0001307624 · Accession: 0000000000-20-003602
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United States securities and exchange commission logo
April 27, 2020
Robert Brantl
Chairman, Chief Executive Officer, and Chief Financial Officer
HYB Holding Corp.
52 Mulligan Lane
Irvington, NY 10533
Re:HYB Holding Corp.
Amendment 1 to Registration Statement on Form 10-12G
Filed April 20, 2020
File No. 0-51012
Dear Mr. Brantl:
We have reviewed your amended registration statement and have the following
comments. In some of our comments we may ask you to provide us information so that 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 that our comments apply to your facts and
circumstances or do not believe that 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 these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our April 15, 2020 letter.
Amendment 1 to Registration Statement on Form 10 filed April 20, 2020
General
1.We note your response to prior comment 4 and disclosure on page 5 that it is unlikely that
you will conduct a public offering while you are a shell company. Please revise to
disclose that you are a blank check company, and disclose the applicability of Rule 419 to
any subsequent offerings as a blank check company. Refer to Interpretation 616.02 in the
Securities Act Rules section of our Compliance and Disclosure Interpretations available
on the Commission's website.
2.We note your response to prior comment 6. Please file the agreements underlying
the loans from your president as exhibits to your registration statement pursuant to
FirstName LastNameRobert Brantl
Comapany NameHYB Holding Corp.
April 27, 2020 Page 2
FirstName LastName
Robert Brantl
HYB Holding Corp.
April 27, 2020
Page 2
Item 601(b)(10)(ii)(A) of Regulation S-K. To the extent these are oral agreements, please
file a written description of the oral agreements as exhibits.
You may contact Charles Eastman, Staff Accountant, at (202) 551-3794 or Jean C. Yu,
Assistant Chief Accountant, at (202) 551-3305 if you have questions regarding comments on the
financial statements and related matters. Please contact Edward M. Kelly, Senior Counsel, at
(202) 551-3728 or Sherry Haywood, Senior Counsel, at (202) 551-33345 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing