SEC Comment Letter 0000000000-25-001420 to Adapti, Inc. (ADTI)
Adapti, Inc.
Date: Feb. 10, 2025 · CIK: 0001420924 · Accession: 0000000000-25-001420
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-53336
Letter
February 10, 2025 Marilu Brassington Interim Chief Accounting Officer Scepter Holdings, Inc. NV 2278 Monitor St Dallas, Texas 75207 Re:Scepter Holdings, Inc. NV Amendment No. 3 to Registration Statement on Form 10 Filed January 30, 2025 File No. 000-53336 Dear Marilu Brassington: We have reviewed your filing and have the following comment(s). Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Amendment No. 3 to Registration Statement on Form 10 Item 1. Business, page 5 1.We note your revised disclosure in response to prior comment 6. Please revise Item 1 to state, as you do on page F-8, that the "Adapti platform is an AI system that was designed to create a proprietary ‘data fingerprint’ for client products data and even the entire company by utilizing third party AI such as ChatGPT, OpenAI or Google AI tools." Statements of Changes in Stockholders' Deficit, page F-6 2.We note your response to prior comment 12. Please further clarify why the number of shares of common stock in 2023 did not change as a result of the correction.
February 10, 2025 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Valeria Franks at 202-551-7705 or Theresa Brillant at 202-551-3307 if you have questions regarding comments on the financial statements and related matters. Please contact Rucha Pandit at 202-551-6022 or Dietrich King at 202-551-8071 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc:Steven Davis
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February 10, 2025
Marilu Brassington
Interim Chief Accounting Officer
Scepter Holdings, Inc. NV
2278 Monitor St
Dallas, Texas 75207
Re:Scepter Holdings, Inc. NV
Amendment No. 3 to Registration Statement on Form 10
Filed January 30, 2025
File No. 000-53336
Dear Marilu Brassington:
We have reviewed your filing and have the following comment(s).
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Amendment No. 3 to Registration Statement on Form 10
Item 1. Business, page 5
1.We note your revised disclosure in response to prior comment 6. Please revise Item 1
to state, as you do on page F-8, that the "Adapti platform is an AI system that was
designed to create a proprietary ‘data fingerprint’ for client products data and even the
entire company by utilizing third party AI such as ChatGPT, OpenAI or Google AI
tools."
Statements of Changes in Stockholders' Deficit, page F-6
2.We note your response to prior comment 12. Please further clarify why the number of
shares of common stock in 2023 did not change as a result of the correction.
February 10, 2025
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
Please contact Valeria Franks at 202-551-7705 or Theresa Brillant at 202-551-3307 if
you have questions regarding comments on the financial statements and related
matters. Please contact Rucha Pandit at 202-551-6022 or Dietrich King at 202-551-8071 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Steven Davis