SEC Company Response from New You, Inc. (CIK 0001372184) — Oct 21, 2021
New You, Inc. (CIK 0001372184)
Date: Oct. 21, 2021 · CIK: 0001372184 · Accession: 0001493152-21-025959
AI Filing Summary & Sentiment
File numbers found in text: 024-11562
Referenced dates: July 16, 2021
Letter
VIA EDGAR Offering Statement on Form 1-A Filed June 23, 2021 File No. 024-11562
Re: New You, Inc.
Dear Ms. Ansart:
We write on behalf of New You, Inc. (the “Company”) in response to comments by the United States Securities and Exchange Commission (the “Commission”) in its letter dated July 16, 2021, commenting on the Company’s Offering Statement on Form 1-A filed June 23, 2021 (the “Offering Statement”).
Titling and paragraph numbering of the comments listed below corresponds to the titling and numbering used in the Commission’s comment letter.
Form 1-A filed June 23, 2021
Cover Page
1. Please revise your price range and/or volume to comply with the requirements of Rule 253(b). In this regard, we note the high end of the range would result in the company’s proceeds exceeding the maximum permitted amount for a Tier 2 offering. To the extent you elect to reduce the number of shares being offered, please update your Dilution section accordingly.
Rule 262(d) Bad Actor Disclosure, page 31
Response: In response to this comment, the Company has amended the Offering Statement throughout to reflect a maxim offering price of $0.125 and a maximum offering amount of no more that $50 million.
2. We note your disclosure on page 31 concerning the October 11, 2002 order barring Mr. Frankovich from association with any NASD member in any capacity. Please provide us with your analysis explaining why the order constitutes a qualifying event under the Rule 262(b) exception of Regulation A.
Response: As reported in the Company’s Current Report on Form 8-K filed October 8, 2021, Mr. Frankovich has resigned from all officer and director positions with the Company. Accordingly, the Company believes that the disqualifications set forth in Rule 262 are no longer applicable. The Offering Statement has been amended where applicable to reflect that Mr. Frankovich is no longer an officer or director of the Company.
Jessica Ansart
United States Securities and Exchange Commission
October 21, 2021
Page 2 of 2
Please feel free to contact me should you require additional information at (775) 234-5221 or jlaxague@cronelawgroup.com.
THE CRONE LAW GROUP, P.C.
By: /s/ Joe Laxague
Joe Laxague, Esq.
Show Raw Text
CORRESP
1
filename1.htm
VIA
EDGAR
October
21, 2021
THE
UNITED STATES SECURITIES
AND
EXCHANGE COMMISSION
Washington,
D.C. 20549
Attn:
Jessica Ansart
Re:
New
You, Inc.
Offering
Statement on Form 1-A
Filed
June 23, 2021
File
No. 024-11562
Dear
Ms. Ansart:
We
write on behalf of New You, Inc. (the “Company”) in response to comments by the United States Securities and Exchange Commission
(the “Commission”) in its letter dated July 16, 2021, commenting on the Company’s Offering Statement on Form 1-A filed
June 23, 2021 (the “Offering Statement”).
Titling
and paragraph numbering of the comments listed below corresponds to the titling and numbering used in the Commission’s comment
letter.
Form
1-A filed June 23, 2021
Cover
Page
1.
Please revise your price range and/or volume to comply with the requirements of Rule 253(b). In this regard, we note the high end of
the range would result in the company’s proceeds exceeding the maximum permitted amount for a Tier 2 offering. To the extent
you elect to reduce the number of shares being offered, please update your Dilution section accordingly.
Rule
262(d) Bad Actor Disclosure, page 31
Response:
In response to this comment, the Company has amended the Offering Statement throughout to reflect a maxim offering price of $0.125 and
a maximum offering amount of no more that $50 million.
2.
We note your disclosure on page 31 concerning the October 11, 2002 order barring Mr. Frankovich from association with any NASD
member in any capacity. Please provide us with your analysis explaining why the order constitutes a qualifying event under the Rule
262(b) exception of Regulation A.
Response:
As reported in the Company’s Current Report on Form 8-K filed October 8, 2021, Mr. Frankovich has resigned from all officer and
director positions with the Company. Accordingly, the Company believes that the disqualifications set forth in Rule 262 are no longer
applicable. The Offering Statement has been amended where applicable to reflect that Mr. Frankovich is no longer an officer or director
of the Company.
Jessica
Ansart
United
States Securities and Exchange Commission
October
21, 2021
Page
2 of 2
Please
feel free to contact me should you require additional information at (775) 234-5221 or jlaxague@cronelawgroup.com.
THE
CRONE LAW GROUP, P.C.
By:
/s/
Joe Laxague
Joe
Laxague, Esq.