SEC Comment Letter 0000000000-25-001593 to iQSTEL Inc (IQST)
iQSTEL Inc
Date: Feb. 12, 2025 · CIK: 0001527702 · Accession: 0000000000-25-001593
AI Filing Summary & Sentiment
File numbers found in text: 000-55984
Referenced dates: December 4, 2024, February 5, 2025
Letter
February 12, 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 February 5, 2025 FIle No. 000-55984 Dear Alvaro Quintana Cardona: We have reviewed your February 5, 2025 response to our comment letter and have the following comments. 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 January 27, 2025 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 1.We note your response to prior comment 1 and your response to comment 2 in your letter dated December 4, 2024. Disclose as part of your revenue recognition policy disclosure your basis for reporting revenue on a gross basis. In your response to this comment, please provide us example disclosure of what you will provide in future filings. We note your response to prior comment 1. Please expand your revenue recognition policy, business, and MD&A disclosures in future filings so that the nature of your revenue generating business including your customers, the services you provide, your performance obligations, the vendor networks you utilize, and the cash 2.
February 12, 2025 Page 2 flows in your arrangements are wholly transparent to readers, consistent with what was communicated to us in your letters dated February 5, 2025 and December 4, 2024. In this regard, an illustration of the usage and provision of services similar to what you provided to us in your response may be helpful. In your response to this comment please provide us with examples of the disclosures you will provide. 3.We note in your response to prior comment 1 you refer to an answer-seizure ratio ("ASR"). Please tell us whether management uses key performance indicators or usage metrics, such as ASR, in managing the business. If so, please disclose and discuss in future filings or explain why you believe the metrics would not be key indicators of the Company’s operating performance. Refer to Item 303(a) of Regulation S-K and Section III.B.1 of SEC Release No. 33-8350. 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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February 12, 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 February 5, 2025
FIle No. 000-55984
Dear Alvaro Quintana Cardona:
We have reviewed your February 5, 2025 response to our comment letter and have the
following comments.
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 January
27, 2025 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
1.We note your response to prior comment 1 and your response to comment 2 in your
letter dated December 4, 2024. Disclose as part of your revenue recognition policy
disclosure your basis for reporting revenue on a gross basis. In your response to this
comment, please provide us example disclosure of what you will provide in future
filings.
We note your response to prior comment 1. Please expand your revenue
recognition policy, business, and MD&A disclosures in future filings so that the
nature of your revenue generating business including your customers, the services you
provide, your performance obligations, the vendor networks you utilize, and the cash 2.
February 12, 2025
Page 2
flows in your arrangements are wholly transparent to readers, consistent with what
was communicated to us in your letters dated February 5, 2025 and December 4,
2024. In this regard, an illustration of the usage and provision of services similar to
what you provided to us in your response may be helpful. In your response to this
comment please provide us with examples of the disclosures you will provide.
3.We note in your response to prior comment 1 you refer to an answer-seizure ratio
("ASR"). Please tell us whether management uses key performance indicators or
usage metrics, such as ASR, in managing the business. If so, please disclose and
discuss in future filings or explain why you believe the metrics would not be key
indicators of the Company’s operating performance. Refer to Item 303(a) of
Regulation S-K and Section III.B.1 of SEC Release No. 33-8350.
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