SEC Comment Letter for Livento Group, (LIVG) — Mar 18, 2015
Livento Group, Inc.
Date: March 18, 2015 · CIK: 0001593549 · Accession: 0000000000-15-016041
AI Filing Summary & Sentiment
File numbers found in text: 333-192997
Letter
March 18, 2015 Via E -Mail Ali Kharazmi Chief Executive Officer NuGene International, Inc. 720 Paularino Avenue Costa Mesa, California 92626
Re: NuGene International, Inc. Amendment No. 1 to Form 8-K Filed March 4, 2015 File No. 333-192997
Dear Mr. Kharazmi :
We have reviewed your filing an d 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 these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Executive Compensation, page 55
Summary Compensation Table, page 55
1. We note your response to comment 20 in our letter date d February 2, 2015. Please revise the summary compensation table to include the compensation information required by Item 402(n) of Regulation S -K for the named executive officers of Nugene Inc. for the fiscal year ended 2013 and NuGene International , Inc. for the fiscal year ended 2014 . The compensation of Ms. Kurland is not required since she is not a part of the surviving entity . Please refer to Item 5.01(a)(8) and footnote s 63 and 64 in SEC Release 33-8587 .
You may contact Jenn Do, Staff Accountant at (202) 551-3743 or, in her absence, Terence O’Brien, Accounting Branch Chief at (202) 551 -3355 if you have questions regarding
Ali Kharazmi NuGene International, Inc. March 18, 2015 Page 2
comments on the financial statements and related matters. Please contact Sherry Haywood, Staff Attorney at (202) 551 -3345 or, in her a bsence, me at (202) 551 -3760 with any other questions.
Sincerely,
/s/ Pamela Long
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March 18, 2015 Via E -Mail Ali Kharazmi Chief Executive Officer NuGene International, Inc. 720 Paularino Avenue Costa Mesa, California 92626 Re: NuGene International, Inc. Amendment No. 1 to Form 8-K Filed March 4, 2015 File No. 333-192997 Dear Mr. Kharazmi : We have reviewed your filing an d 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 these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Executive Compensation, page 55 Summary Compensation Table, page 55 1. We note your response to comment 20 in our letter date d February 2, 2015. Please revise the summary compensation table to include the compensation information required by Item 402(n) of Regulation S -K for the named executive officers of Nugene Inc. for the fiscal year ended 2013 and NuGene International , Inc. for the fiscal year ended 2014 . The compensation of Ms. Kurland is not required since she is not a part of the surviving entity . Please refer to Item 5.01(a)(8) and footnote s 63 and 64 in SEC Release 33-8587 . You may contact Jenn Do, Staff Accountant at (202) 551-3743 or, in her absence, Terence O’Brien, Accounting Branch Chief at (202) 551 -3355 if you have questions regarding Ali Kharazmi NuGene International, Inc. March 18, 2015 Page 2 comments on the financial statements and related matters. Please contact Sherry Haywood, Staff Attorney at (202) 551 -3345 or, in her a bsence, me at (202) 551 -3760 with any other questions. Sincerely, /s/ Pamela Long Pamela Long Assistant Director cc: Via E -mail Aaron Grunfeld, Esq.