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SEC Comment Letter for Synergy CHC Corp. (SNYR) (CIK 0001562733) (SNYRQ) — May 30, 2014

Synergy CHC Corp. (SNYR) (CIK 0001562733)
Date: May 30, 2014 · CIK: 0001562733 · Accession: 0000000000-14-027540

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File numbers found in text: 000-55098

Referenced dates: May 12, 2014

Date
May 29, 2014
Author
/s/ Steve Lo
Form
UPLOAD
Company
Synergy CHC Corp. (SNYR) (CIK 0001562733)

Letter

May 29, 2014 Via E-mail Mark Suponitsky Chief Executive Officer Synergy Strips Corp. 2105 Burton Branch Road Algood, TN 38506

Re: Synergy Strips Corp. Form 8 -K Filed May 7 , 2014 Response Dated May 27, 2014 File No. 000-55098

Dear Mr. Suponitsky :

We have reviewed your filing and response 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 within five business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your fac ts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.

Form 8 -K Filed on May 7 , 2014

Change in Accountant

1. We note from your response to our letter dated May 12, 2014 that “[a]s of the date of this letter, [you] have not yet determined if the registrant’s auditor will be replaced, but [you] will timely disclo se any change of auditor when it occurs under Item 4.01 of Form 8 -K by providing all information required by Item 304 of Regulation S -K.” Please be advised when the reverse merger was consummated, Synergy Strips Corp. assumed the 1934 Exchange Act reporti ng obligations from Oro Capital Corp. In addition, concurrent with the reverse merger, a change of accountant is presumed to have occurred with the auditor

Mark Suponitsky Synergy Strips Corp. May 29, 2014 Page 2

of the operating company becoming the company’s new independent registered accountant. Please amen d the Form 8 -K to provide all information required by Item 304 of Regulation S -K to report your change in accountant.

Please contact me at 202 -551-3394 if you have questions regar ding these comments and related matters.

Sincerely,
/s/ Steve Lo

Show Raw Text
May 29, 2014

Via E-mail
Mark Suponitsky
Chief Executive Officer
Synergy Strips Corp.
2105 Burton Branch Road
Algood, TN 38506

Re: Synergy Strips Corp.
 Form 8 -K
Filed May 7 , 2014
Response Dated May 27, 2014
 File No. 000-55098

Dear Mr. Suponitsky :

We have reviewed your filing  and response  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 within five business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your fac ts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 8 -K Filed on May 7 , 2014

Change in Accountant

1. We note from your response to our letter dated May 12, 2014 that “[a]s of the date of this
letter, [you] have not yet determined if the registrant’s auditor will be replaced, but [you]
will timely disclo se any change of auditor when it occurs under Item 4.01 of Form 8 -K
by providing all information required by Item 304 of Regulation S -K.”  Please be advised
when the reverse merger was consummated, Synergy Strips Corp. assumed the 1934
Exchange Act reporti ng obligations from Oro Capital Corp.  In addition, concurrent with
the reverse merger, a change of accountant is presumed to have occurred with the auditor

Mark Suponitsky
Synergy Strips Corp.
May 29, 2014
Page 2

 of the operating company becoming the company’s new independent registered
accountant.  Please amen d the Form 8 -K to provide all information required by Item 304
of Regulation S -K to report your change in accountant.

Please  contact me at 202 -551-3394  if you have questions regar ding these comments and related
matters.

Sincerely,

 /s/ Steve Lo

Steve Lo
Staff Accountant