SEC Comment Letter for HAMMER TECHNOLOGY HOLDINGS (HMMR) — Jun 28, 2024
HAMMER TECHNOLOGY HOLDINGS CORP.
Date: June 28, 2024 · CIK: 0001539680 · Accession: 0000000000-24-007325
AI Filing Summary & Sentiment
File numbers found in text: 001-35876
Letter
United States securities and exchange commission logo June 28, 2024 Erik B. Levitt Principal Financial Officer Hammer Fiber Optics Holdings Corp 6151 Lake Osprey Drive Sarasota, FL 34 240 Re:Hammer Fiber Optics Holdings Corp Form 10-K filed on February 16, 2024 Form 10-Q filed on March 27, 2024 Correspondence filed on June 11, 2024 File No. 001-35876 Dear Erik B. Levitt: We have reviewed your June 11, 2024 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 May 14, 2024 letter. Correspondence filed on June 11, 2024 Certificiations, page 25 1.The Certifications pursuant to Rule 13a-14(a) or 15d-14(a) of the Securities Exchange Act Rules ("Sec. 302 certification"), and 18 U.S.C. Section 1350 as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 ("Sec. 906 certification") must signed by both CEO and the CFO of the company in future periodic filings. Note 3 - Summary of significant accounting policies, page F-18 2.We noted your response to our prior comment 4, and we also note that you have recorded customer contracts in aggregate of $4,477,113 as indefinite live assets. Please clarify why you have concluded that the customer contract qualify as an indefinite lived intangible assets. Refer to ASC 805-20-55-25. Describe your consideration of whether the
FirstName LastNameErik B. Levitt Comapany Name Hammer Fiber Optics Holdings Corp June 28, 2024 Page 2 FirstName LastName Erik B. Levitt Hammer Fiber Optics Holdings Corp June 28, 2024 Page 2 customer might not renew and become a customer of a competitor or going out of business(e.g. customer turnover). Please contact Becky Chow at 202-551-6524 or Stephen Krikorian at 202-551-3488 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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United States securities and exchange commission logo
June 28, 2024
Erik B. Levitt
Principal Financial Officer
Hammer Fiber Optics Holdings Corp
6151 Lake Osprey Drive
Sarasota, FL 34 240
Re:Hammer Fiber Optics Holdings Corp
Form 10-K filed on February 16, 2024
Form 10-Q filed on March 27, 2024
Correspondence filed on June 11, 2024
File No. 001-35876
Dear Erik B. Levitt:
We have reviewed your June 11, 2024 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 May 14,
2024 letter.
Correspondence filed on June 11, 2024
Certificiations, page 25
1.The Certifications pursuant to Rule 13a-14(a) or 15d-14(a) of the Securities Exchange
Act Rules ("Sec. 302 certification"), and 18 U.S.C. Section 1350 as adopted pursuant to
Section 906 of the Sarbanes-Oxley Act of 2002 ("Sec. 906 certification") must signed by
both CEO and the CFO of the company in future periodic filings.
Note 3 - Summary of significant accounting policies, page F-18
2.We noted your response to our prior comment 4, and we also note that you have
recorded customer contracts in aggregate of $4,477,113 as indefinite live assets. Please
clarify why you have concluded that the customer contract qualify as an indefinite lived
intangible assets. Refer to ASC 805-20-55-25. Describe your consideration of whether the
FirstName LastNameErik B. Levitt
Comapany Name Hammer Fiber Optics Holdings Corp
June 28, 2024 Page 2
FirstName LastName
Erik B. Levitt
Hammer Fiber Optics Holdings Corp
June 28, 2024
Page 2
customer might not renew and become a customer of a competitor or going out of
business(e.g. customer turnover).
Please contact Becky Chow at 202-551-6524 or Stephen Krikorian at 202-551-3488 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology