SEC Comment Letter for GME INNOTAINMENT, INC. (CIK 0001382112) — May 15, 2020
GME INNOTAINMENT, INC. (CIK 0001382112)
Date: May 15, 2020 · CIK: 0001382112 · Accession: 0000000000-20-004361
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File numbers found in text: 024-11139
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United States securities and exchange commission logo
May 15, 2020
Yves R. Michel
Chief Executive Officer
GME Innotainment, Inc.
208 East 51st Street, Suite 170
New York, NY 10022
Re:GME Innotainment, Inc.
Amendment No. 4 to Offering Statement on Form 1-A
Filed May 5, 2020
File No. 024-11139
Dear Mr. Michel:
We have reviewed your amended offering statement 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 this letter by amending your offering statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your offering statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 4 to Offering Statement on Form 1-A filed May 5, 2020
Offering Summary, page 8
1.We note that you provide the number of shares of common stock outstanding as of
December 31, 2019. Please revise to provide the number of shares outstanding as of the
most recent practicable date. Please make corresponding revisions to your disclosure in
the section entitled Principal Stockholders. Refer to Item 12(a) of Form 1-A.
Risk Factors, page 9
2.Please revise to discuss the effects, if any, that COVID-19 has had on your business,
including, what management expects its future impact will be, how management is
responding to evolving events, and how it is planning for COVID-19-related uncertainties
going forward.
FirstName LastNameYves R. Michel
Comapany NameGME Innotainment, Inc.
May 15, 2020 Page 2
FirstName LastName
Yves R. Michel
GME Innotainment, Inc.
May 15, 2020
Page 2
Certain Relationships and Related Party Transactions, page 45
3.Please revise your disclosure in this section to discuss the transactions mentioned in Notes
4 and 7 on pages 68 and 74, respectively.
You may contact Claire Erlanger, Staff Accountant, at 202-551-3301 or Melissa
Raminpour, Accounting Branch Chief, at 202-551-3379 if you have questions regarding
comments on the financial statements and related matters. Please contact Thomas Jones, Staff
Attorney, at 202-551-3602 or Erin Purnell, Senior Attorney, at 202-551-3454 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Andrew Coldicutt, Esq