SEC Company Response from Kartoon Studios, Inc. (TOON) (CIK 0001355848) (TOON) — Jan 17, 2018
Kartoon Studios, Inc. (TOON) (CIK 0001355848)
Date: Jan. 17, 2018 · CIK: 0001355848 · Accession: 0001683168-18-000164
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-221683
Referenced dates: January 4, 2018
Letter
Chrysler Center
666 Third Avenue
New York, NY
212-935-3000
212-983-3115 fax
www.mintz.com
January 17, 2018
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Ms. Laura Nicholson, Special Counsel, Office of Transportation and Leisure
Re: Genius Brands International, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed December 22, 2017
File No. 333-221683
Ladies and Gentlemen:
We are submitting this letter on behalf of Genius Brands International, Inc. (the “Company”) in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received by letter dated January 4, 2018 (the “Comment Letter”) from Ms. Laura Nicholson, Special Counsel, Office of Transportation and Leisure, to Andy Heyward, the Company’s Chief Executive Officer, relating to the above-referenced Amendment No. 1 to Registration Statement on Form S-1 of the Company filed with the Commission on December 22, 2017 (the “Registration Statement”). We are concurrently submitting via EDGAR this letter and Amendment No. 2 to the Registration Statement (“Amendment No. 2”).
For convenient reference, we have set forth below in italics the Staff’s comments set forth in the Comment Letter and have keyed the Company’s response to the numbering of the comments and the heading used in the Comment Letter.
Executive Compensation, page 36
1. Please update your executive and director compensation disclosure to provide the information called for by Item 402 of Regulation S-K for your fiscal year ended December 31, 2017. For guidance, refer to Question 117.05 of Regulation S-K Compliance and Disclosure Interpretations on our website.
Response: In response to the Staff’s comment, we have updated the executive and director compensation disclosure on pages 36-37 of Amendment No. 2 to reflect compensation information as of the Company’s fiscal year ended December 31, 2017.
* * * * *
We hope that the above response will be acceptable to the Staff. Please do not hesitate to contact me at 212-692-6732 or jschultz@mintz.com with any comments or questions regarding Amendment No. 2 and this letter. We thank you for your time and attention.
Sincerely,
/s/ Jeffrey Schultz
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filename1.htm
Chrysler
Center
666 Third Avenue
New York, NY
10017
212-935-3000
212-983-3115
fax
www.mintz.com
January 17, 2018
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Ms. Laura Nicholson, Special Counsel, Office of Transportation
and Leisure
Re: Genius Brands International, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed December 22, 2017
File No. 333-221683
Ladies and Gentlemen:
We are submitting this
letter on behalf of Genius Brands International, Inc. (the “Company”) in response to comments from the staff
(the “Staff”) of the Securities and Exchange Commission (the “Commission”) received by letter
dated January 4, 2018 (the “Comment Letter”) from Ms. Laura Nicholson, Special Counsel, Office of Transportation
and Leisure, to Andy Heyward, the Company’s Chief Executive Officer, relating to the above-referenced Amendment No. 1 to
Registration Statement on Form S-1 of the Company filed with the Commission on December 22, 2017 (the “Registration Statement”).
We are concurrently submitting via EDGAR this letter and Amendment No. 2 to the Registration Statement (“Amendment No.
2”).
For convenient reference,
we have set forth below in italics the Staff’s comments set forth in the Comment Letter and have keyed the Company’s
response to the numbering of the comments and the heading used in the Comment Letter.
Executive Compensation, page 36
1. Please update your executive and director compensation disclosure to provide the information
called for by Item 402 of Regulation S-K for your fiscal year ended December 31, 2017. For guidance, refer to Question 117.05 of
Regulation S-K Compliance and Disclosure Interpretations on our website.
Response: In response
to the Staff’s comment, we have updated the executive and director compensation disclosure on pages 36-37 of Amendment No.
2 to reflect compensation information as of the Company’s fiscal year ended December 31, 2017.
* * * * *
We hope that the above response will be
acceptable to the Staff. Please do not hesitate to contact me at 212-692-6732 or jschultz@mintz.com with any comments or questions
regarding Amendment No. 2 and this letter. We thank you for your time and attention.
Sincerely,
/s/ Jeffrey Schultz
Jeffrey Schultz
cc: Genius Brands International, Inc.
Andy Heyward, Chief Executive Officer
Rebecca D. Hershinger, Chief Financial Officer
Gregory B. Payne,
Chief Operating Officer and Executive Vice President – Legal/Business Affairs