SEC Comment Letter 0000000000-25-000842 to iQSTEL Inc (IQST)
iQSTEL Inc
Date: Jan. 27, 2025 · CIK: 0001527702 · Accession: 0000000000-25-000842
AI Filing Summary & Sentiment
File numbers found in text: 000-55984
Letter
January 27, 2025 Alvaro Quintana Cardona Chief Financial Officer iQSTEL Inc 300 Aragon Avenue, Suite 375 Coral Gables, FL 33134 Re:iQSTEL Inc Form 10-K for the Year Ended December 31, 2023 Response dated December 4, 2024 FIle No. 000-55984 Dear Alvaro Quintana Cardona: We have reviewed your December 4, 2024 response to our comment letter and have the following comment. 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. Unless we note otherwise, any references to prior comments are to comments in our November 8, 2024 letter. Form 10-K for the Year Ended December 31, 2023 Audited Financial Statements Note 2. Summary of Significant Accounting Policies Revenue Recognition, page F-11
We note in your response to prior comment 2 you identified several services including "International Voice Termination for carriers" and “International SMS termination.” We also note costs of revenue “primarily consist of usage charges for calls terminated in vendors’ networks." Please explain to us the Company’s role in these service arrangements and clarify if the Company is as an intermediary for calls terminated on another vendors’ network. Also, please explain: How the Company controls these services immediately prior to the service being transferred to the customer when it appears these services are provided on another •1.
January 27, 2025 Page 2 entity’s network in an instant. •We note with respect to "International Voice Termination for carriers" and “International SMS termination” services you said the Company is primarily responsible for fulfilling the promise to provide the specified service. If true, please confirm that it is understood by your customers that the Company is not physically capable of providing termination services on another entities network. •Tell us if the terms of your customer contracts or your other communications (for example, marketing materials) with your customers indicate that the Company or a third party is responsible for providing the call termination service. •Tell us if for a particular call, there are several vendor networks to choose from and if the Company has discretion in selecting which vendor network to utilize to fulfill an end consumer order. •Please also clarify for us the cash flows in these arrangements. It is unclear if you first collect from customers and then share a portion of the revenue with the network vendors or if your customers remit the net proceeds to you after deducting the third party network vendors’ share.
Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage at 202- 551-3361 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology
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January 27, 2025
Alvaro Quintana Cardona
Chief Financial Officer
iQSTEL Inc
300 Aragon Avenue, Suite 375
Coral Gables, FL 33134
Re:iQSTEL Inc
Form 10-K for the Year Ended December 31, 2023
Response dated December 4, 2024
FIle No. 000-55984
Dear Alvaro Quintana Cardona:
We have reviewed your December 4, 2024 response to our comment letter and have
the following comment.
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.
Unless we note otherwise, any references to prior comments are to comments in our
November 8, 2024 letter.
Form 10-K for the Year Ended December 31, 2023
Audited Financial Statements
Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page F-11
We note in your response to prior comment 2 you identified several services
including "International Voice Termination for carriers" and “International SMS
termination.” We also note costs of revenue “primarily consist of usage charges for
calls terminated in vendors’ networks." Please explain to us the Company’s role in
these service arrangements and clarify if the Company is as an intermediary for calls
terminated on another vendors’ network. Also, please explain:
How the Company controls these services immediately prior to the service being
transferred to the customer when it appears these services are provided on another •1.
January 27, 2025
Page 2
entity’s network in an instant.
•We note with respect to "International Voice Termination for carriers" and
“International SMS termination” services you said the Company is primarily
responsible for fulfilling the promise to provide the specified service. If true,
please confirm that it is understood by your customers that the Company is not
physically capable of providing termination services on another entities network.
•Tell us if the terms of your customer contracts or your other communications (for
example, marketing materials) with your customers indicate that the Company or
a third party is responsible for providing the call termination service.
•Tell us if for a particular call, there are several vendor networks to choose from
and if the Company has discretion in selecting which vendor network to utilize to
fulfill an end consumer order.
•Please also clarify for us the cash flows in these arrangements. It is unclear if you
first collect from customers and then share a portion of the revenue with the
network vendors or if your customers remit the net proceeds to you after
deducting the third party network vendors’ share.
Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage at 202-
551-3361 if you have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of Corporation Finance
Office of Technology