SEC Comment Letter for ACQUIRED SALES CORP (LIFD) (CIK 0001391135) (LIFD) — Jul 16, 2021
ACQUIRED SALES CORP (LIFD) (CIK 0001391135)
Date: July 16, 2021 · CIK: 0001391135 · Accession: 0000000000-21-008803
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File numbers found in text: 333-232985
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United States securities and exchange commission logo
July 16, 2021
Gerard M. Jacobs
Chief Executive Officer
Acquired Sales Corp.
4227 Habana Avenue
Jacksonville, FL 32217
Re:Acquired Sales Corp.
Amendment No. 4 to Registration Statement on Form S-1
Filed July 2, 2021
File No. 333-232985
Dear Mr. Jacobs:
We have reviewed your amended registration 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 registration 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 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 June 28, 2021 letter.
Amendment No. 4 to Registration Statement on Form S-1
Notes to the Consolidated Financial Statements
Note 1 - Basis of Presentation and Significant Accounting Policies
Revenue
Disaggregation of Revenue, page 107
1.Your response to prior comment 1 to not include disaggregation of revenue by sales of
raw materials to customers, sales of products to private label clients, and sales of products
to wholesalers, distributors, and end users is unclear to us. In this regard, it is unclear from
your response why "the rapidly evolving nature of our industry," would prohibit the
disaggregation of historical revenue. Please advise further. As such, we repeat our prior
comment to disaggregate revenues by sales of raw materials to customers, sales of
FirstName LastNameGerard M. Jacobs
Comapany NameAcquired Sales Corp.
July 16, 2021 Page 2
FirstName LastName
Gerard M. Jacobs
Acquired Sales Corp.
July 16, 2021
Page 2
products to private label clients, and sales of products to wholesalers, distributors, and end
users, which you identify as your business streams on page 106.
Note 5 - The Company's Investments, page 112
2.Your response to prior comment 2 is unclear to us. In this regard, you explain the
assessments that you perform at each reporting period related to your investments, but
then further state that you will revise your disclosures in future filings. However, your
current disclosure on page 112 states that review your investments during the fourth
quarter of each year. Please revise or advise accordingly.
You may contact Ryan Rohn, Senior Staff Accountant, at (202) 551-3739 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the financial statements and related matters. Please contact Edwin Kim, Staff
Attorney, at (202) 551-3297 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: David S. Hunt, Esq.