SEC Comment Letter for RYVYL Inc. (RTB) (CIK 0001419275) (RTB) — Sep 19, 2014
RYVYL Inc. (RTB) (CIK 0001419275)
Date: Sept. 19, 2014 · CIK: 0001419275 · Accession: 0000000000-14-047076
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34294
Letter
September 18 , 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 April 15, 201 4 File No. 001-34294
Dear M r. Yuan :
We have reviewed your filing an d have the following comment . In our comment , 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 comment applies 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 this comment , 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 have reviewed your response to comment 1, and we note that your revised disclosure is still vague regarding the services you provide. We note that you have earned consulting fees for providing advisory services and that you have incurred expenses for advisory services, but in future filings, please provide a much more comprehensive discussion of the specific services you provide and specific expenses you incur to give users of your financial statements a clearer picture of your business and the factors that can impact it. Please provide us with your proposed disclosure.
We urge all persons who are responsible for the accuracy and adequacy of the discl osure in the filing to be certain 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. September 18 , 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.
If you have any questions, you may contact Eric McPhee at (202) 551 -3693 or me at (202) 551-3429.
Sincerely,
/s/ Kristi Marrone
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September 18 , 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 April 15, 201 4 File No. 001-34294 Dear M r. Yuan : We have reviewed your filing an d have the following comment . In our comment , 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 comment applies 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 this comment , 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 have reviewed your response to comment 1, and we note that your revised disclosure is still vague regarding the services you provide. We note that you have earned consulting fees for providing advisory services and that you have incurred expenses for advisory services, but in future filings, please provide a much more comprehensive discussion of the specific services you provide and specific expenses you incur to give users of your financial statements a clearer picture of your business and the factors that can impact it. Please provide us with your proposed disclosure. We urge all persons who are responsible for the accuracy and adequacy of the discl osure in the filing to be certain 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. September 18 , 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. 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