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Correspondence 0001493152-23-008910 from Livento Group, Inc. (NUGN) (CIK 0001593549) (LIVG)

Livento Group, Inc. (NUGN) (CIK 0001593549)
Date: March 24, 2023 · CIK: 0001593549 · Accession: 0001493152-23-008910

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File numbers found in text: 000-56457

Date
March 24, 2023
Author
Not clearly detected
Form
CORRESP
Company
Livento Group, Inc. (NUGN) (CIK 0001593549)

Letter

Re:

FRANK J. HARITON ● ATTORNEY - AT - LAW

Dobbs Ferry Road ● White Plains ● New York 10607 ● (Tel) (914) 674-4373 ● (Fax) (914) 693-2963 ● (e-mail) hariton@sprynet.com

March 24, 2023

Division of Corporation Finance

Office of Technology

Securities and Exchange Commission

Washington, D.C. 20549

Livento Group, Inc. (the “Company”)

Amendment Number 8 to Registration Statement on Form 10-12G

File No. 000-56457

Ladies and Gentlemen:

We are filing amendment number 8 in response to staff comments and to updated and correct minor errors in prior filings. Our responses to staff comments are as follows:

Business Trends in Our Markets, page 9

1. In light of your disclosure that your software product was developed to run portfolio analyses and to provide improved portfolio management and performance, please revise the assertion that the company does not have to comply with regulatory requirements.

We have removed the sentence that says our software is not subject to regulation.

Liquidity and Capital Resources, page 24

2. On page 25 you state, “Each movie is produced in separate company, so risk of failure is mitigated for Livento as a holding company.” Please clarify this statement. Tell us who produces the movies. Tell us if the production company is a related party as defined in ASC 850-10-20.

Pursuant to ASC 850-10-20, which defines the term as “related parties” or “affiliates” these movies are not produced by any “related parties”, “affiliates” or includes other parties that are de facto agents of the variable interest holder based on the definition of ASC 850-10-20. The companies where distributor finances the movie in its final phase are owned by a third party that do not meet the definition of ASC 850-10-20. The production company is owned by a third party, that is NOT directly or indirectly through one or more intermediaries, controls, is controlled by, or is under common control with an entity. The movies are produced by our internal team. The companies we cooperate with are Cygnus Film Group, LLC and The Avenue Entertainment, LLC.

3. With regard to your real estate project, you state on page 26 that “The project was financed by 65% by bank loans which will be repaid on the sale of the units.” It does not appear that these bank loans are recorded in your financial statements. Please revise accordingly.

Contractual Obligations

The Company’s Real Estate Project was financed by 65% bank loan. Since, December 31, 2022, the contractual obligations of the Company have changed as follows:

● The outstanding balance of these loans was repaid by application of the proceeds of sales of the Units. There is a pending legal procedure on the Cadastral office and land register to free the units and clients’ money to complete the transaction. We expect this to be finalized before 31th of March 2023.

Description of Registrant’s Securities to be Registered Common Shares, page 31

4. Your disclosure that your Certificate of Incorporation authorizes you to issue 500,000,000 shares of common stock appears to be inconsistent with the last amendment to your Certificate of Incorporation (filed as Exhibit 3.9), which authorizes 800,000,000 shares of common stock. Please revise or advise. Similarly, we note updates to your disclosure regarding the amount of authorized shares of blank check preferred stock. Please explain why this change was made and file an updated Certificate of Incorporation, if applicable.

We inadvertently failed to file an amendment reducing our Authorized common shares as an exhibit. It is now filed.

Consolidated Statements of Equity, page 39

5. On page 31 you list various share issuances during the past two fiscal years. Please reconcile these share issuances to your Consolidated Statements of Equity.

Below is a detailed breakdown of all movements in Equity

Series A Preferred Stock Series C Preferred Stock Series D Preferred Stock Common stock Additional Paid in capital Accumulated Deficit Shareholder’s equity

No. of shares Amount No. of shares Amount No. of shares Amount No. of shares Amount

Balance as of January 1, 2021, - - - - 21,918,062 -11748760

New preferred Shares issued to take-over the company by former management - - - - - - -

Common shares issued for services - - - - - - 634,110,594 -63,411 - -

Series C Preferred Shares issued for services - - 28,000 - - - - -3 - -

Coversion of Series C Preferred Shares to Common shares - - -28,000 -3 - - 2,800,000 -277 -

Coversion of Series C Preferred Shares to Common shares with specific condition - - -1,917,720 -192 - - 1,917,720 - - -

Loan Settlement - - - - - - 67,146,478 -6,715 - -

Common shares settlement - - - - - - 666,666 -67 - -

Changes in additional Paid in capital from other companies - - - - - - - - 10,227,343 - 10,227,343

Net Loss for the year ended - - - - - - - - - -320320 -320,320

Balance as of December 31, 2021 - - - - 765,895,613 76,590 32,074,932 -12,069,080 20,082,442

Date of Transaction Transaction type (e.g., new issuance, cancellation, shares returned to treasury) Number of Shares Issued (or cancelled) Class of Securities Individual/ Entity Shares were issued to (entities must have individual with voting / investment control disclosed). Reason for share issuance (e.g., for cash or debt conversion)-OR-Nature of Services Provided Restricted or Unrestricted as of this filing. Exemption or Registration Type.

04/05/2021 New 000 000 Common Milan Hoffman Services Restricted

04/20/2021 Cancelled -2 328 000 Common Milan Hoffman Services Restricted

04/20/2021 New 328 000 Common Michael Kopstick Services Restricted

05/07/2021 Cancelled -10 500 000 Common Milan Hoffman Services Restricted

05/07/2021 New 500 000 Common Michael Kopstick Services Restricted

06/09/2021 Cancelled -2 000 000 Common Milan Hoffman Services Restricted

06/09/2021 New 000 000 Common James Cowland Services Restricted

06/17/2021 Cancelled -2 000 000 Common Milan Hoffman Services Restricted

06/17/2021 New 000 000 Common Paul Segura Jr. Services Restricted

07/02/2021 Cancelled -20 000 000 Common Milan Hoffman Services Restricted

07/02/2021 New 000 000 Common Frank J. Hariton Services Restricted

07/08/2021 Cancelled -37 800 000 Common Milan Hoffman Services Restricted

07/08/2021 New 800 000 Common Judah Aaron Sternhill Services Restricted

07/21/2021 Cancelled -10 000 000 Common Milan Hoffman Services Restricted

07/23/2021 New 000 000 Common Milan Hoffman Services Restricted

07/23/2021 New Common ALI KHARAZMI Conversion from Preferred to Common Restricted

07/23/2021 New Common SAEED KHARAZMI Conversion from Preferred to Common Restricted

08/13/2021 New

Preferred A Milan Hoffman Super Voting Stock Restricted

08/13/2021 Cancelled -1 917 720 Preferred C Milan Hoffman Conversion from Preferred to Common Restricted

08/17/2021 New Common Sandy Miles Services Restricted

08/17/2021 New Preferred C Sandy Miles Services Restricted

09/03/2021 New 399 416 Common Eagle Equities LLC, Yanky Borenstein Loan Settlement Unrestricted

09/13/2021 New 225 034 Common EMA Financial LLC, John Scholz Loan Settlement Unrestricted

10/05/2021 New Preferred C James Cowland Services Restricted

10/18/2021 New Common Sharni Brodesky Purchase Restricted

10/19/2021 New Common Dayna R. Shereck Purchase Restricted

11/17/2021 Cancelled -10 689 406 Common Milan Hoffman Cancellation Restricted

11/17/2021 New 689 406 Common Eagle Equities LLC,Yanky Borenstien Loan Settlement Unrestricted

11/18/2021 Cancelled -20 000 000 Common Milan Hoffman Cancellation Restricted

11/18/2021 New 428 572 Common Power Up Lending Group Ltd., Curt Kramer Loan Settlement Unrestricted

11/30/2021 New 285 583 Common EMA Financial, Felicia Preston LLC Loan Settlement Unrestricted

12/02/2021 New 583 333 Common Labrys Fund LP,TJ Silverman Loan Settlement Unrestricted

12/06/2021 New 160 000 Common SBI Investments LLC, Jonathan Juchno Loan Settlement Unrestricted

12/06/2021 New 960 000 Common Power Up Lending Group Ltd.,Curt Kramer Loan Settlement Restricted

12/07/2021 Cancelled -30 000 000 Common Milan Hoffman Cancellation Restricted

12/13/2021 New 415 134 Common Auctus Fund LLC, Lou Posner Loan Settlement Unrestricted

12/17/2021 Cancelled - 8 000 Preferred C Sandy Miles Conversion from Preferred to Common Restricted

12/17/2021 New Common Sandy Miles Purchase Restricted

12/17/2021 Cancelled - 20 000 Preferred C James Cowland Conversion from Preferred to Common Restricted

12/17/2021 New 000 000 Common James Cowland Services Restricted

Series A Preferred Stock

Series C Preferred Stock

Series D Preferred Stock

Common stock

Additional Paid in capital Accumulated Deficit Shareholder’s

equity

No. of shares Amount No. of shares Amount No. of shares Amount No. of shares Amount

Balance as of January 1, 2021,

-

-

-

-

765,895,613

76,590

32,074,932

- 12,069,080 20,082,442

Conversion of Note -

-

-

-

-

-

49,586,549

4,959

- 4,959 -

-

Issuance of Series C Preferred Shares to David Stybr and their cancelation -

-

-

-

-

-

-

-

-

-

-

Series D Preferred Shares issued for services -

-

-

-

141,630

1,416

-

-

- 1,416 -

-

Sales of Series D Preferred Shares -

-

-

-

69,714

-

-

365,803

-

366,500

Cancelation of Common shares and their transformation to Series C Preferred Shares -

-

1,164,826

-

-

-116,482,594

-11,648

11,532

-

Cancelation of Common shares by former director -

-

-

-

-

-

-500,000,000

-50,000

50,000

-

-

Sales of Series C Preferred Shares -

-

39,600

-

-

-

-

-4

-

-

Net Loss for the year ended -

-

-

-

-

-

-

-

-

- 1,460,395 - 1,460,395

Changes in additional Paid in capital from other companies -

-

-

-

-

-

-

-

-65

-

-

1,204,426

211,344

2,113

198,999,568

19,900

32,495,823

- 13,529,475 18,988,482

Date of Transaction Transaction type (e.g., new issuance, cancellation, shares returned to treasury) Number of Shares Issued (or cancelled) Class of Securities Individual/ Entity Shares were issued to (entities must have individual with voting / investment control disclosed). Reason for share issuance (e.g., for cash or debt conversion)-OR-Nature of Services Provided Restricted or Unrestricted as of this filing. Exemption or Registration Type.

01/04/2022 New 482 781 Common Sandy Miles Conversion of Note Unrestricted

02/02/2022 New 691 925 Common Adam R. Long, Puerto Rico, Oasis Capital LLC Conversion of Note Unrestricted

02/25/2022 Cancellation -58 682 594 Common Milan Hoffman Cancellation Restricted

02/25/2022 New Preferred C Milan Hoffman Services/payment Restricted

02/28/2022 New Preferred C Judah A. Sternhill Purchase Restricted

02/28/2022 New Preferred C Frank J. Hariton Services/payment Restricted

02/28/2022 Cancellation -500 000 000 Common Milan Hoffman Return to unissued authorized status Restricted

02/28/2022 Cancellation -37 800 000 Common Judah A. Sternhill Purchase Restricted

02/28/2022 Cancellation -20 000 000 Common Frank J. Hariton Services/payment Restricted

03/01/2022 New 898 682 Common Tiger Trout Capital LLC, Puerto Rico, Alan Masley Conversion of Note Unrestricted

03/03/2022 New 032 080 Common Abra Prince Conversion of Note Unrestricted

03/14/2022 New 000 000 Preferred David Štýbr Control block Restricted

03/23/2022 New 482 781 Common Kalimdor LLC, Ales Kudrna Conversion of Note Unrestricted

06/21/2022 Cancellation -5 000 000 Preferred C David Štýbr Cancellation Restricted

07/19/2022 New 000 000 Common Kalimdor LLC, Ales Kudrna Conversion of Note Unrestricted

07/19/2022 New

Show Raw Text
CORRESP
1
filename1.htm

FRANK
J. HARITON  ● ATTORNEY - AT - LAW

1065
Dobbs Ferry Road ● White Plains ● New York 10607 ● (Tel) (914) 674-4373 ● (Fax) (914) 693-2963 ● (e-mail)
hariton@sprynet.com

    March
    24, 2023

Division
of Corporation Finance

Office
of Technology

Securities
and Exchange Commission

Washington,
D.C. 20549

    Re:

    Livento
    Group, Inc. (the “Company”)

    Amendment
    Number 8 to Registration Statement on Form 10-12G

    File
    No. 000-56457

Ladies
and Gentlemen:

We
are filing amendment number 8 in response to staff comments and to updated and correct minor errors in prior filings. Our responses to
staff comments are as follows:

Business
Trends in Our Markets, page 9

1.
In light of your disclosure that your software product was developed to run portfolio analyses and to provide improved portfolio management
and performance, please revise the assertion that the company does not have to comply with regulatory requirements.

We
have removed the sentence that says our software is not subject to regulation.

Liquidity
and Capital Resources, page 24

2.
On page 25 you state, “Each movie is produced in separate company, so risk of failure is mitigated for Livento as a holding company.”
Please clarify this statement. Tell us who produces the movies. Tell us if the production company is a related party as defined in ASC
850-10-20.

Pursuant
to ASC 850-10-20, which defines the term as “related parties” or “affiliates” these movies are not produced by
any “related parties”, “affiliates” or includes other parties that are de facto agents of the variable interest
holder based on the definition of ASC 850-10-20. The companies where distributor finances the movie in its final phase are owned by a
third party that do not meet the definition of ASC 850-10-20. The production company is owned by a third party, that is NOT directly
or indirectly through one or more intermediaries, controls, is controlled by, or is under common control with an entity. The movies are
produced by our internal team. The companies we cooperate with are Cygnus Film Group, LLC and The Avenue Entertainment, LLC.

3.
With regard to your real estate project, you state on page 26 that “The project was financed by 65% by bank loans which will be
repaid on the sale of the units.” It does not appear that these bank loans are recorded in your financial statements. Please revise
accordingly.

Contractual
Obligations

The
Company’s Real Estate Project was financed by 65% bank loan. Since, December 31, 2022, the contractual obligations of the Company
have changed as follows:

    ●
    The
    outstanding balance of these loans was repaid by application of the proceeds of sales of the Units. There is a pending legal procedure
    on the Cadastral office and land register to free the units and clients’ money to complete the transaction. We expect this
    to be finalized before 31th of March 2023.

Description
of Registrant’s Securities to be Registered Common Shares, page 31

4.
Your disclosure that your Certificate of Incorporation authorizes you to issue 500,000,000 shares of common stock appears to be inconsistent
with the last amendment to your Certificate of Incorporation (filed as Exhibit 3.9), which authorizes 800,000,000 shares of common stock.
Please revise or advise. Similarly, we note updates to your disclosure regarding the amount of authorized shares of blank check preferred
stock. Please explain why this change was made and file an updated Certificate of Incorporation, if applicable.

We
inadvertently failed to file an amendment reducing our Authorized common shares as an exhibit. It is now filed.

Consolidated
Statements of Equity, page 39

5.
On page 31 you list various share issuances during the past two fiscal years. Please reconcile these share issuances to your Consolidated
Statements of Equity.

Below
is a detailed breakdown of all movements in Equity

    Series
    A Preferred Stock
    Series
    C Preferred Stock
    Series
    D Preferred Stock
    Common
    stock
    Additional
    Paid in capital
    Accumulated
    Deficit
    Shareholder’s
    equity

    No.
    of shares
    Amount
    No.
    of shares
    Amount
    No.
    of shares
    Amount
    No.
    of shares
    Amount

    Balance
    as of January 1, 2021,
    -
    -
    1917720
    192
    -
    -
    59254155
    5925
    21,918,062
    -11748760
    10175419

    New
    preferred Shares issued to take-over the company by former management
    100
    0
    -
    -
    -
    -
    -
    -
    0
    -
    0

    Common
    shares issued for services
    -
    -
    -
    -
    -
    -
    634,110,594
    63411
    -63,411
    -
    -

    Series
    C Preferred Shares issued for services
    -
    -
    28,000
    3
    -
    -
    -
    -
    -3
    -
    -

    Coversion
    of Series C Preferred Shares to Common shares
    -
    -
    -28,000
    -3
    -
    -
    2,800,000
    280
    -277
    -
    0

    Coversion
    of Series C Preferred Shares to Common shares with specific condition
    -
    -
    -1,917,720
    -192
    -
    -
    1,917,720
    192
    -
    -
    -

    Loan
    Settlement
    -
    -
    -
    -
    -
    -
    67,146,478
    6715
    -6,715
    -
    -

    Common
    shares settlement
    -
    -
    -
    -
    -
    -
    666,666
    67
    -67
    -
    -

    Changes
    in additional Paid in capital from other companies
    -
    -
    -
    -
    -
    -
    -
    -
    10,227,343
    -
    10,227,343

    Net
    Loss for the year ended
    -
    -
    -
    -
    -
    -
    -
    -
    -
    -320320
    -320,320

    Balance
    as of December 31, 2021
    100
    0
    -
    -
    -
    -
    765,895,613
    76,590
    32,074,932
    -12,069,080
    20,082,442

    Date
    of Transaction
    Transaction
    type (e.g., new issuance, cancellation, shares returned to treasury)
     Number
    of Shares Issued (or cancelled)
    Class
    of Securities
    Individual/
    Entity Shares were issued to (entities must have individual with voting / investment control disclosed).
    Reason
    for share issuance (e.g., for cash or debt conversion)-OR-Nature of Services Provided
    Restricted
    or Unrestricted as of this filing.
    Exemption
    or Registration Type.

    04/05/2021
    New
     700
    000 000
    Common
    Milan
    Hoffman
    Services
    Restricted
    144

    04/20/2021
    Cancelled
    -2
    328 000
    Common
    Milan
    Hoffman
    Services
    Restricted
    144

    04/20/2021
    New
     2
    328 000
    Common
    Michael
    Kopstick
    Services
    Restricted
    144

    05/07/2021
    Cancelled
    -10
    500 000
    Common
    Milan
    Hoffman
    Services
    Restricted
    144

    05/07/2021
    New
     10
    500 000
    Common
    Michael
    Kopstick
    Services
    Restricted
    144

    06/09/2021
    Cancelled
    -2
    000 000
    Common
    Milan
    Hoffman
    Services
    Restricted
    144

    06/09/2021
    New
     2
    000 000
    Common
    James
    Cowland
    Services
    Restricted
    144

    06/17/2021
    Cancelled
    -2
    000 000
    Common
    Milan
    Hoffman
    Services
    Restricted
    144

    06/17/2021
    New
     2
    000 000
    Common
    Paul
    Segura Jr.
    Services
    Restricted
    144

    07/02/2021
    Cancelled
    -20
    000 000
    Common
    Milan
    Hoffman
    Services
    Restricted
    144

    07/02/2021
    New
     20
    000 000
    Common
    Frank
    J. Hariton
    Services
    Restricted
    144

    07/08/2021
    Cancelled
    -37
    800 000
    Common
    Milan
    Hoffman
    Services
    Restricted
    144

    07/08/2021
    New
     37
    800 000
    Common
    Judah
    Aaron Sternhill
    Services
    Restricted
    144

    07/21/2021
    Cancelled
    -10
    000 000
    Common
    Milan
    Hoffman
    Services
    Restricted
    144

    07/23/2021
    New
     4
    000 000
    Common
    Milan
    Hoffman
    Services
    Restricted
    144

    07/23/2021
    New
    958
    860
    Common
    ALI
    KHARAZMI
    Conversion
    from Preferred to Common
    Restricted
    144

    07/23/2021
    New
    958
    860
    Common
    SAEED
    KHARAZMI
    Conversion
    from Preferred to Common
    Restricted
    144

    08/13/2021
    New
     100

    Preferred
    A
    Milan
    Hoffman
    Super
    Voting Stock
    Restricted
    144

    08/13/2021
    Cancelled
    -1
    917 720
    Preferred
    C
    Milan
    Hoffman
    Conversion
    from Preferred to Common
    Restricted
    144

    08/17/2021
    New
    800
    000
    Common
    Sandy
    Miles
    Services
    Restricted
    144

    08/17/2021
    New
    8
    000
    Preferred
    C
    Sandy
    Miles
    Services
    Restricted
    144

    09/03/2021
    New
     6
    399 416
    Common
    Eagle
    Equities LLC, Yanky Borenstein
    Loan
    Settlement
    Unrestricted

    09/13/2021
    New
     2
    225 034
    Common
    EMA
    Financial LLC, John Scholz
    Loan
    Settlement
    Unrestricted

    10/05/2021
    New
    20
    000
    Preferred
    C
    James
    Cowland
    Services
    Restricted
    144

    10/18/2021
    New
    333
    333
    Common
    Sharni
    Brodesky
    Purchase
    Restricted
    144

    10/19/2021
    New
    333
    333
    Common
    Dayna
    R. Shereck
    Purchase
    Restricted
    144

    11/17/2021
    Cancelled
    -10
    689 406
    Common
    Milan
    Hoffman
    Cancellation
    Restricted
    144

    11/17/2021
    New
     10
    689 406
    Common
    Eagle
    Equities LLC,Yanky Borenstien
    Loan
    Settlement
    Unrestricted

    11/18/2021
    Cancelled
    -20
    000 000
    Common
    Milan
    Hoffman
    Cancellation
    Restricted
    144

    11/18/2021
    New
     5
    428 572
    Common
    Power
    Up Lending Group Ltd., Curt Kramer
    Loan
    Settlement
    Unrestricted

    11/30/2021
    New
     8
    285 583
    Common
    EMA
    Financial, Felicia Preston LLC
    Loan
    Settlement
    Unrestricted

    12/02/2021
    New
     4
    583 333
    Common
    Labrys
    Fund LP,TJ Silverman
    Loan
    Settlement
    Unrestricted

    12/06/2021
    New
     6
    160 000
    Common
    SBI
    Investments LLC, Jonathan Juchno
    Loan
    Settlement
    Unrestricted

    12/06/2021
    New
     3
    960 000
    Common
    Power
    Up Lending Group Ltd.,Curt Kramer
    Loan
    Settlement
    Restricted
    144

    12/07/2021
    Cancelled
    -30
    000 000
    Common
    Milan
    Hoffman
    Cancellation
    Restricted
    144

    12/13/2021
    New
     19
    415 134
    Common
    Auctus
    Fund LLC, Lou Posner
    Loan
    Settlement
    Unrestricted

    12/17/2021
    Cancelled
    -
    8 000
    Preferred
    C
    Sandy
    Miles
    Conversion
    from Preferred to Common
    Restricted
    144

    12/17/2021
    New
    800
    000
    Common
    Sandy
    Miles
    Purchase
    Restricted
    144

    12/17/2021
    Cancelled
    -
    20 000
    Preferred
    C
    James
    Cowland
    Conversion
    from Preferred to Common
    Restricted
    144

    12/17/2021
    New
     2
    000 000
    Common
    James
    Cowland
    Services
    Restricted
    144

    Series
    A Preferred Stock

    Series
    C Preferred Stock

    Series
    D Preferred Stock

    Common
    stock

    Additional
    Paid in capital
    Accumulated
    Deficit
    Shareholder’s

                                                                                equity

    No.
    of shares
    Amount
    No.
    of shares
    Amount
    No.
    of shares
    Amount
    No.
    of shares
    Amount

    Balance
    as of January 1, 2021,
     100

     0

    -

     -

     -

    -

     765,895,613

     76,590

     32,074,932

    -
    12,069,080
     20,082,442

    Conversion
    of Note
    -

    -

    -

     -

     -

    -

     49,586,549

     4,959

    -
    4,959
     -

     -

    Issuance
    of Series C Preferred Shares to David Stybr and their cancelation
    -

    -

    -

     -

     -

    -

    -

     -

    -

     -

     -

    Series
    D Preferred Shares issued for services
    -

    -

    -

     -

     141,630

     1,416

    -

     -

    -
    1,416
     -

     -

    Sales
    of Series D Preferred Shares
    -

    -

    -

     -

     69,714

    697

    -

     -

    365,803

     -

    366,500

    Cancelation
    of Common shares and their transformation to Series C Preferred Shares
    -

    -

     1,164,826

    116

     -

    -

    -116,482,594

    -11,648

    11,532

     -

     0

    Cancelation
    of Common shares by former director
    -

    -

    -

     -

     -

    -

    -500,000,000

    -50,000

    50,000

     -

     -

    Sales
    of Series C Preferred Shares
    -

    -

    39,600

    4

     -

    -

    -

     -

    -4

     -

     -

    Net
    Loss for the year ended
    -

    -

    -

     -

     -

    -

    -

     -

    -

    -
    1,460,395
    -
    1,460,395

    Changes
    in additional Paid in capital from other companies
    -

    -

    -

     -

     -

    -

    -

     -

    -65

     -

    -
    65

     100

     0

     1,204,426

    120

     211,344

     2,113

     198,999,568

     19,900

     32,495,823

    -
    13,529,475
    18,988,482

    Date
    of Transaction
    Transaction
    type (e.g., new issuance, cancellation, shares returned to treasury)
     Number
    of Shares Issued (or cancelled)
    Class
    of Securities
    Individual/
    Entity Shares were issued to (entities must have individual with voting / investment control disclosed).
    Reason
    for share issuance (e.g., for cash or debt conversion)-OR-Nature of Services Provided
    Restricted
    or Unrestricted as of this filing.
    Exemption
    or Registration Type.

    01/04/2022
    New
     9
    482 781
    Common
    Sandy
    Miles
    Conversion
    of Note
    Unrestricted

    02/02/2022
    New
     15
    691 925
    Common
    Adam
    R. Long, Puerto Rico, Oasis Capital LLC
    Conversion
    of Note
    Unrestricted

    02/25/2022
    Cancellation
    -58
    682 594
    Common
    Milan
    Hoffman
    Cancellation
    Restricted
    144

    02/25/2022
    New
    586
    826
    Preferred
    C
    Milan
    Hoffman
    Services/payment
    Restricted
    144

    02/28/2022
    New
    378
    000
    Preferred
    C
    Judah
    A. Sternhill
    Purchase
    Restricted
    144

    02/28/2022
    New
    200
    000
    Preferred
    C
    Frank
    J. Hariton
    Services/payment
    Restricted
    144

    02/28/2022
    Cancellation
    -500
    000 000
    Common
    Milan
    Hoffman
    Return
    to unissued authorized status
    Restricted
    144

    02/28/2022
    Cancellation
    -37
    800 000
    Common
    Judah
    A. Sternhill
    Purchase
    Restricted
    144

    02/28/2022
    Cancellation
    -20
    000 000
    Common
    Frank
    J. Hariton
    Services/payment
    Restricted
    144

    03/01/2022
    New
     15
    898 682
    Common
    Tiger
    Trout Capital LLC, Puerto Rico, Alan Masley
    Conversion
    of Note
    Unrestricted

    03/03/2022
    New
     9
    032 080
    Common
    Abra
    Prince
    Conversion
    of Note
    Unrestricted

    03/14/2022
    New
     5
    000 000
    Preferred
    David
    Štýbr
    Control
    block
    Restricted
    144

    03/23/2022
    New
     9
    482 781
    Common
    Kalimdor
    LLC, Ales Kudrna
    Conversion
    of Note
    Unrestricted

    06/21/2022
    Cancellation
    -5
    000 000
    Preferred
    C
    David
    Štýbr
    Cancellation
    Restricted
    144

    07/19/2022
    New
     10
    000 000
    Common
    Kalimdor
    LLC, Ales Kudrna
    Conversion
    of Note
    Unrestricted

    07/19/2022
    New