SEC Comment Letter for RYVYL Inc. (RTB) (CIK 0001419275) (RTB) — Aug 27, 2014
RYVYL Inc. (RTB) (CIK 0001419275)
Date: Aug. 27, 2014 · CIK: 0001419275 · Accession: 0000000000-14-043139
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34294
Letter
August 26, 2014 Via E -mail Frank Yuan Chief Executive Officer and President ASAP Expo , Inc. 9436 Jacob Lane Rosemead , CA 91770
Re: ASAP Expo , Inc. Form 10 -K for the Year Ended December 31 , 2013 Filed March 15 , 201 4 File No. 001-34294
Dear M r. Yuan :
We have reviewed your filing an d 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 within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstance s or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.
Form 10 -K for the Year Ended December 31, 2013
Item 6. Management’s Discussion and Analysis or Plan of Operations, page 9
1. We note your disclosure that your revenues are derived from providing advisory services in real estate acquisition deals, and that you did more deals in 20 13 than you did in 2012. In future filings, please provide a much more comprehensive discussion of your revenues, how they are derived and the reasons for period -to-period changes, as well as a comprehensive discussion of your expenses to give users of yo ur financial statements a clearer picture of your business and the factors that can impact it. Please provide us with your proposed revisions.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be c ertain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are
Frank Yuan ASAP Expo , Inc. August 26, 2014 Page 2
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceedin g initiated by the Commission or any person under the federal securities laws of the United States.
If you have any questions, you may contact Eric McPhee at (202) 551 -3693 or me at (202) 551 -3429.
Sincerely,
/s/ Kristi Marrone
Show Raw Text
August 26, 2014 Via E -mail Frank Yuan Chief Executive Officer and President ASAP Expo , Inc. 9436 Jacob Lane Rosemead , CA 91770 Re: ASAP Expo , Inc. Form 10 -K for the Year Ended December 31 , 2013 Filed March 15 , 201 4 File No. 001-34294 Dear M r. Yuan : We have reviewed your filing an d 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 within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstance s or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Form 10 -K for the Year Ended December 31, 2013 Item 6. Management’s Discussion and Analysis or Plan of Operations, page 9 1. We note your disclosure that your revenues are derived from providing advisory services in real estate acquisition deals, and that you did more deals in 20 13 than you did in 2012. In future filings, please provide a much more comprehensive discussion of your revenues, how they are derived and the reasons for period -to-period changes, as well as a comprehensive discussion of your expenses to give users of yo ur financial statements a clearer picture of your business and the factors that can impact it. Please provide us with your proposed revisions. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be c ertain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are Frank Yuan ASAP Expo , Inc. August 26, 2014 Page 2 in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceedin g initiated by the Commission or any person under the federal securities laws of the United States. If you have any questions, you may contact Eric McPhee at (202) 551 -3693 or me at (202) 551 -3429. Sincerely, /s/ Kristi Marrone Kristi Marrone Senior Accountant