SEC Comment Letter for Quarta-Rad, Inc. (QURT) (CIK 0001549631) (QURT) — May 4, 2016
Quarta-Rad, Inc. (QURT) (CIK 0001549631)
Date: May 4, 2016 · CIK: 0001549631 · Accession: 0000000000-16-074843
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Letter
Mail Stop 3030 May 3 , 2016 Victor Shvetsky Chairman, Chief Executive Officer, Secretary and Principal Financial and Accounting Officer Quarta -Rad, Inc. 1201 N. Orange Street Suite 700 Wilmington, DE 19801
Re: Quarta -Rad, Inc. Amendment No. 4 to Registration Statement on Form S-1 Filed April 15, 2016 File No. 333 -196078
Dear Mr. Shvetsky:
We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the requested informa tion. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 25, 2014 letter .
Certain Relationships . . ., page 35
1. We note your revisions in response to prior comment 6; however, your disclosure here and on page F -12 continue to disclose different amount s of inventory you purchased during 2014 and the amount s you owed as of the end of 2014. Please revise.
Changes I n and Disagreements With Accountants on Accounting and Financial Disclosure, page
2. Please revise your filing to include letters filed as an exhibit to this registration statement that is addressed to the Commission from Anton & Chia and Hartley Moore Ac countancy
Victor Shvetsky Quarta -Rad, Inc. May 3 , 2016 Page 2
Corporation, your former accountants, stating whether they agree with the statements made by you under Item 304(a) of Regulation S -K and, if not, stating the respects in which they do not agree. Refer to the guidance in Item 304(a)(3) of Regulati on S-K.
Financial Statements, page 43
Report of Independent Registered Public Accounting Firm, page F -2
3. We note the disclosure on page F -12 of the restatement of your previously issued financial statements. Please have your independent auditor modify its report to add an explanatory paragraph that refers to the restatement and to be dual -dated. Refer to paragraphs 68, 69, 72 and 73 of PCAOB AU Section 508.
You may contact Tara Harkins at (202) 551 -3639 or Kevin Kuhar, Accounting Branch Chief , at (202) 551 -3662 if you have questions regarding comments on the financial statements and related matters. Please contact Geoff Kruczek at (202) 551 -3641 or me at (202) 551 -3528 with any other questions.
Sincerely,
/s/ Amanda Ravitz
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Mail Stop 3030 May 3 , 2016 Victor Shvetsky Chairman, Chief Executive Officer, Secretary and Principal Financial and Accounting Officer Quarta -Rad, Inc. 1201 N. Orange Street Suite 700 Wilmington, DE 19801 Re: Quarta -Rad, Inc. Amendment No. 4 to Registration Statement on Form S-1 Filed April 15, 2016 File No. 333 -196078 Dear Mr. Shvetsky: We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested informa tion. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 25, 2014 letter . Certain Relationships . . ., page 35 1. We note your revisions in response to prior comment 6; however, your disclosure here and on page F -12 continue to disclose different amount s of inventory you purchased during 2014 and the amount s you owed as of the end of 2014. Please revise. Changes I n and Disagreements With Accountants on Accounting and Financial Disclosure, page 41 2. Please revise your filing to include letters filed as an exhibit to this registration statement that is addressed to the Commission from Anton & Chia and Hartley Moore Ac countancy Victor Shvetsky Quarta -Rad, Inc. May 3 , 2016 Page 2 Corporation, your former accountants, stating whether they agree with the statements made by you under Item 304(a) of Regulation S -K and, if not, stating the respects in which they do not agree. Refer to the guidance in Item 304(a)(3) of Regulati on S-K. Financial Statements, page 43 Report of Independent Registered Public Accounting Firm, page F -2 3. We note the disclosure on page F -12 of the restatement of your previously issued financial statements. Please have your independent auditor modify its report to add an explanatory paragraph that refers to the restatement and to be dual -dated. Refer to paragraphs 68, 69, 72 and 73 of PCAOB AU Section 508. You may contact Tara Harkins at (202) 551 -3639 or Kevin Kuhar, Accounting Branch Chief , at (202) 551 -3662 if you have questions regarding comments on the financial statements and related matters. Please contact Geoff Kruczek at (202) 551 -3641 or me at (202) 551 -3528 with any other questions. Sincerely, /s/ Amanda Ravitz Amanda Ravitz Assistant Director Office of Electronics and Machinery cc: Michael T. Connette, Esq. Donald P. Hateley, Esq.