Correspondence 0001213900-24-073422 from Synergy CHC Corp. (SNYR)
Synergy CHC Corp.
Date: Aug. 28, 2024 · CIK: 0001562733 · Accession: 0001213900-24-073422
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-280556
Referenced dates: August 27, 2024
Letter
NELSON MULLINS RILEY & SCARBOROUGH LLP
ATTORNEYS AND COUNSELORS AT LAW
W. David Mannheim
T: 919.329.3804
david.mannheim@nelsonmullins.com
301 Hillsborough Street, Suite 1400
Raleigh, NC 27603
T: 919.329.3800 F: 919.329.3799
nelsonmullins.com
August 28, 2024
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attention: Tracie Mariner
Vanessa Robertson
Tamika Sheppard
Joe McCann
RE: Synergy CHC Corp.
Amendment No. 2 to Registration Statement on Form S-1
Filed August 14, 2024
File No. 333-280556
Ladies and Gentlemen:
On behalf of Synergy CHC Corp. (the “Company”), we are hereby responding to the letter dated August 27, 2024 (the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission (“SEC” or the “Commission”), regarding the Company’s Amendment No. 2 to Registration Statement on Form S-1 filed on August 14, 2024 (the “Registration Statement”). In response to the Comment Letter and to update certain information in the Registration Statement, the Company is submitting its Amendment No. 3 to the Registration Statement (the “Amended Registration Statement”) with the Commission today. The numbered paragraphs below correspond to the numbered comments in the Comment Letter, and the Staff’s comments are presented in bold italics.
Amendment No. 2 to Registration Statement on Form S-1
Certain Relationships and Related Party Transactions, page 72
1. We note your revised disclosures in response to prior comment 6. Please revise to disclose whether there are default terms in place, including any rights and remedies in the event you do not receive payment in full on or before the repayment date.
Response: The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has revised its disclosure on page 73 of the Amended Registration Statement.
*****
If you have any additional questions regarding any of our responses or the Amended Registration Statement, please do not hesitate to contact David Mannheim at (919) 329-3804.
Very truly yours,
/s/ W. David Mannheim
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NELSON MULLINS RILEY & SCARBOROUGH LLP
ATTORNEYS AND COUNSELORS AT LAW
W. David Mannheim
T: 919.329.3804
david.mannheim@nelsonmullins.com
301 Hillsborough Street, Suite 1400
Raleigh, NC 27603
T: 919.329.3800 F: 919.329.3799
nelsonmullins.com
August 28, 2024
Division of Corporation Finance
U.S. Securities and Exchange
Commission
100 F Street, N.E.
Washington, DC 20549
Attention:
Tracie Mariner
Vanessa Robertson
Tamika Sheppard
Joe McCann
RE:
Synergy CHC Corp.
Amendment No. 2 to Registration Statement on Form S-1
Filed August 14, 2024
File No. 333-280556
Ladies and Gentlemen:
On behalf of Synergy CHC Corp. (the “Company”),
we are hereby responding to the letter dated August 27, 2024 (the “Comment Letter”) from the staff (the “Staff”)
of the Securities and Exchange Commission (“SEC” or the “Commission”), regarding the Company’s
Amendment No. 2 to Registration Statement on Form S-1 filed on August 14, 2024 (the “Registration Statement”). In response
to the Comment Letter and to update certain information in the Registration Statement, the Company is submitting its Amendment No. 3 to
the Registration Statement (the “Amended Registration Statement”) with the Commission today. The numbered paragraphs
below correspond to the numbered comments in the Comment Letter, and the Staff’s comments are presented in bold italics.
Amendment No. 2 to Registration Statement on Form S-1
Certain Relationships and Related Party Transactions, page 72
1. We note your revised disclosures in response to prior
comment 6. Please revise to disclose whether there are default terms in place, including any rights and remedies in the event you do
not receive payment in full on or before the repayment date.
Response: The Company respectfully acknowledges the Staff’s
comment and advises the Staff that it has revised its disclosure on page 73 of the Amended Registration Statement.
*****
If you have any additional questions regarding
any of our responses or the Amended Registration Statement, please do not hesitate to contact David Mannheim at (919) 329-3804.
Very truly yours,
/s/ W. David Mannheim
W. David Mannheim
cc:
Mike Bradshaw, Nelson Mullins Riley & Scarborough LLP
Jack Ross, Chief Executive Officer, Synergy CHC Corp.