SEC Company Response from GL Brands, Inc. (CIK 0001581545) — Mar 13, 2020
GL Brands, Inc. (CIK 0001581545)
Date: March 13, 2020 · CIK: 0001581545 · Accession: 0001683168-20-000792
AI Filing Summary & Sentiment
File numbers found in text: 000-55687
Letter
Re: GL Brands, Inc.
March 13, 2020
Attn: Tracey Houser; Terence O’Brien
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Life Sciences
100 F Street, N.E.
Washington, DC 20549
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
File No. 000-55687
Form 8-K Filed June 4, 2019
Response Dated March 6, 2020
Ladies and Gentlemen:
GL Brands, Inc. (the “Company”) provides the following response (the “Response Letter”) to the comments contained in the letter (the “Comment Letter”) of the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) dated March 11, 2020, relating to the above-referenced filings.
In response to the following enumerated comments in the Comment Letter, we respectfully submit the following responses:
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, 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.
Response: We confirm that the Company intends to provide the required disclosure when an ineffective conclusion is reached.
Thank you for your assistance and review.
Sincerely,
GL Brands, Inc.
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March 13, 2020
Attn: Tracey Houser; Terence O’Brien
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Life Sciences
100 F Street, N.E.
Washington, DC 20549
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
File No. 000-55687
Form 8-K Filed June 4, 2019
Response Dated March 6, 2020
Ladies and Gentlemen:
GL Brands, Inc. (the “Company”)
provides the following response (the “Response Letter”) to the comments contained in the letter (the “Comment
Letter”) of the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities
and Exchange Commission (the “Commission”) dated March 11, 2020, relating to the above-referenced filings.
In response to the following enumerated
comments in the Comment Letter, we respectfully submit the following responses:
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, 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.
Response: We confirm that the Company
intends to provide the required disclosure when an ineffective conclusion is reached.
Thank you for your assistance and review.
Sincerely,
GL Brands, Inc.
/s/
Brian Moon
Brian Moon
Chief Financial Officer