SEC Company Response from Quarta-Rad, Inc. (QURT) (CIK 0001549631) (QURT) — May 9, 2016
Quarta-Rad, Inc. (QURT) (CIK 0001549631)
Date: May 9, 2016 · CIK: 0001549631 · Accession: 0001493152-16-009566
AI Filing Summary & Sentiment
File numbers found in text: 333-196078
Referenced dates: May 3, 2016, May 3, 2016
Letter
SECURITIES AND EXCHANGE COMMISSION Response to Comment letter dated May 3, 2016 Amendment No. 4 to Form S-1 Filed: February 11, 2015 File No. 333-196078
Dear Ms. Ravitz:
Enclosed is the Pre-Effective Amendment No. 5 to the above Registration Statement. The changes are made in response to the initial Registration Statement and to make appropriate updates. The paragraph numbers below correspond to the numbered comments in your comment letter dated May 3, 2016.
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 amounts of inventory you purchased during 2014 and the amounts you owed as of the end of 2014. Please revise.
Response: We have revised the disclosures on page 35 and on page F-12 to disclose the correct amounts of inventory the Company purchased during 2014 and the amounts it owed as of the end of 2014.
Changes In 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 Accountancy 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 Regulation S-K.
Response: We have revised the filing to include the letters, as exhibits 16.1 and 16.2, to this registration statement that is addressed to the Commission from Anton & Chia and Hartley Moore Accountancy Corporation, the Company’s former accountants, stating that they agree with the statements made by the Company under Item 304(a) of Regulation S-K.
Ms. Amanda Ravitz
May 9, 2016
Page 2 of 2
Financial Statements, page
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.
Response: The Company’s independent auditor has modified its report to add an explanatory paragraph that refers to the restatement and is dual-dated.
We believe the foregoing changes have adequately addressed the SEC’s comments.
If you have any question or require anything further, please feel free to call me at 310-576-4758 or Michael Connette at (424) 777-8800.
Sincerely
yours,
HATELEY
& HAMPTON,
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CORRESP
1
filename1.htm
201
santa monica boulevard
suite
300
santa
monica, ca 90401-2224
Telephone
(310) 576-4758
Facsimile
(310) 388-5899
Email: dhateley@hateleyhampton.com
May 9, 2016
Ms. Amanda Ravitz
SECURITIES AND EXCHANGE COMMISSION
100 F Street, N.E.
Washington, DC 20549
Re:
Quarta-Rad, Inc.
Response to Comment letter dated May 3, 2016
Amendment No. 4 to Form S-1
Filed: February 11, 2015
File No. 333-196078
Dear Ms. Ravitz:
Enclosed is the Pre-Effective
Amendment No. 5 to the above Registration Statement. The changes are made in response to the initial Registration Statement and
to make appropriate updates. The paragraph numbers below correspond to the numbered comments in your comment letter dated May 3,
2016.
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 amounts of inventory you purchased during 2014 and the amounts you
owed as of the end of 2014. Please revise.
Response: We have revised the disclosures on page 35 and on page F-12 to disclose the correct
amounts of inventory the Company purchased during 2014 and the amounts it owed as of the end of 2014.
Changes In 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 Accountancy
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 Regulation S-K.
Response: We have revised the filing to include the letters, as exhibits 16.1 and 16.2, to this
registration statement that is addressed to the Commission from Anton & Chia and Hartley Moore
Accountancy Corporation, the Company’s former accountants, stating that they agree with the
statements made by the Company under Item 304(a) of Regulation S-K.
Ms. Amanda Ravitz
May 9, 2016
Page 2 of 2
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.
Response: The Company’s independent auditor has modified its report to add
an explanatory paragraph that refers to the restatement and is dual-dated.
We believe the foregoing changes have adequately
addressed the SEC’s comments.
If you have any question or require anything
further, please feel free to call me at 310-576-4758 or Michael Connette at (424) 777-8800.
Sincerely
yours,
HATELEY
& HAMPTON,
/s/
Donald P. Hateley
Donald
P. Hateley, Esq., CPA
cc:
Victor Shvetsky, Chief Executive Officer
Michael T. Connette, Esq.