SEC Comment Letter for GL Brands, Inc. (CIK 0001581545) — Mar 11, 2020
GL Brands, Inc. (CIK 0001581545)
Date: March 11, 2020 · CIK: 0001581545 · Accession: 0000000000-20-002175
AI Filing Summary & Sentiment
File numbers found in text: 000-55687
Letter
March 11, 2020 Brian Moon Chief Financial Officer GL Brands, Inc. 3939 Beltline Road, Suite 350 Addison, Texas 75001 Re:GL Brands, Inc. Form 10-K for Fiscal Year Ended June 30, 2019 Filed November 14, 2019 Form 10-Q for Fiscal Quarter Ended September 30, 2019 Filed January 31, 2020 Form 8-K Filed June 4, 2019 File No. 000-55687 Response Dated March 6, 2020 Dear Mr. Moon: We have reviewed your March 6, 2020 response to our comment letter and have the following comment. We may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our February 26, 2020 letter. Form 10-Q for Fiscal Quarter Ended September 30, 2019 Item 4. Controls and Procedures, page 27 1.We note your response to comment 2. When a conclusion is reached that disclosure controls and procedures are ineffective for an interim period, disclosure should be provided for the facts and circumstances that lead to the ineffective conclusion to allow investors to better understand the current control environment. It is unknown whether the same deficiencies identified in the Form 10-K remain the same in the interim period, especially if any new deficiencies have been identified during the period. In this regard,
FirstName LastNameBrian Moon Comapany NameGL Brands, Inc. March 11, 2020 Page 2 FirstName LastName Brian Moon GL Brands, Inc. March 11, 2020 Page 2 we note that you did not file the Article 8-04 of Regulation S-X financial statements and Article 8-05 of Regulation S-X pro forma financial information for ECS Labs when required. Please confirm to us that you will provide the disclosure when an ineffective conclusion is reached. You may contact Tracey Houser, Staff Accountant, at (202) 551-3736, or Terence O’Brien, Accounting Branch Chief, at (202) 551-3355, if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Life Sciences
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March 11, 2020
Brian Moon
Chief Financial Officer
GL Brands, Inc.
3939 Beltline Road, Suite 350
Addison, Texas 75001
Re:GL Brands, Inc.
Form 10-K for Fiscal Year Ended June 30, 2019
Filed November 14, 2019
Form 10-Q for Fiscal Quarter Ended September 30, 2019
Filed January 31, 2020
Form 8-K Filed June 4, 2019
File No. 000-55687
Response Dated March 6, 2020
Dear Mr. Moon:
We have reviewed your March 6, 2020 response to our comment letter and have the
following comment. We may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
February 26, 2020 letter.
Form 10-Q for Fiscal Quarter Ended September 30, 2019
Item 4. Controls and Procedures, page 27
1.We note your response to comment 2. When a conclusion is reached that disclosure
controls and procedures are ineffective for an interim period, disclosure should be
provided for the facts and circumstances that lead to the ineffective conclusion to allow
investors to better understand the current control environment. It is unknown whether the
same deficiencies identified in the Form 10-K remain the same in the interim period,
especially if any new deficiencies have been identified during the period. In this regard,
FirstName LastNameBrian Moon
Comapany NameGL Brands, Inc.
March 11, 2020 Page 2
FirstName LastName
Brian Moon
GL Brands, Inc.
March 11, 2020
Page 2
we note that you did not file the Article 8-04 of Regulation S-X financial statements and
Article 8-05 of Regulation S-X pro forma financial information for ECS Labs when
required. Please confirm to us that you will provide the disclosure when an ineffective
conclusion is reached.
You may contact Tracey Houser, Staff Accountant, at (202) 551-3736, or Terence
O’Brien, Accounting Branch Chief, at (202) 551-3355, if you have questions regarding
comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Life Sciences