SEC Comment Letter for PALVELLA THERAPEUTICS, INC. (PVLA) (CIK 0001583648) (PVLA) — Oct 15, 2013
PALVELLA THERAPEUTICS, INC. (PVLA) (CIK 0001583648)
Date: Oct. 15, 2013 · CIK: 0001583648 · Accession: 0000000000-13-056565
AI Filing Summary & Sentiment
Reasoning
Letter
October 15, 2013 Via E -mail Aleksandrs Sviks Marika Inc. Chief Executive Officer 2360 C orporate Circle , Suite 400 Henderson, NV 89074
Re: Marika Inc. Amendment No.1 to Registration Statement on Form S -1 Filed September 30, 2013 File No. 333 -190728
Dear Mr. Sviks:
We have reviewed your registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so that we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
Management’s Discussion and Analysis, page 14
1. We note your response to comment 7 in our letter dated September 16 , 2013 . We understand the function of the contract, however, our comment concerned why you consider the contract to be material given that there is no assurance that Superakcijas will provide you with any minimum amount of business. Please advise.
Industry Overview, page 21
2. We note your response to comment 13 in our letter dated September 16 , 2013 . We reissue our comment. Please revise your description under “Our Services” to make explicit t hat you will also provide business concierge services as well and distinguish such services, as appropriate, from other concierge services.
Please contact Elizabeth Sellars , Staff Accountant , at (202) 551 -3348 or Jason Niethamer, Assistant Chief Accountant at (202) 551 -3855 if you have any questions regarding comments on
Aleksandrs Sviks Marika Inc. October 15, 2013 Page 2
the financial statements and related matters. Please contact Scott Anderegg, Staff Attorney , at (202) 551 -3342, or me at (202) 551 -3720 with any other questions.
Sincerely,
/s/ Mara L. Ransom
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October 15, 2013 Via E -mail Aleksandrs Sviks Marika Inc. Chief Executive Officer 2360 C orporate Circle , Suite 400 Henderson, NV 89074 Re: Marika Inc. Amendment No.1 to Registration Statement on Form S -1 Filed September 30, 2013 File No. 333 -190728 Dear Mr. Sviks: We have reviewed your registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so that we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. Management’s Discussion and Analysis, page 14 1. We note your response to comment 7 in our letter dated September 16 , 2013 . We understand the function of the contract, however, our comment concerned why you consider the contract to be material given that there is no assurance that Superakcijas will provide you with any minimum amount of business. Please advise. Industry Overview, page 21 2. We note your response to comment 13 in our letter dated September 16 , 2013 . We reissue our comment. Please revise your description under “Our Services” to make explicit t hat you will also provide business concierge services as well and distinguish such services, as appropriate, from other concierge services. Please contact Elizabeth Sellars , Staff Accountant , at (202) 551 -3348 or Jason Niethamer, Assistant Chief Accountant at (202) 551 -3855 if you have any questions regarding comments on Aleksandrs Sviks Marika Inc. October 15, 2013 Page 2 the financial statements and related matters. Please contact Scott Anderegg, Staff Attorney , at (202) 551 -3342, or me at (202) 551 -3720 with any other questions. Sincerely, /s/ Mara L. Ransom Mara L. Ransom Assistant Director