SEC Comment Letter for Alpine 4 Technologies Ltd. (ALPP) (CIK 0001606698) — Feb 28, 2020
Alpine 4 Technologies Ltd. (ALPP) (CIK 0001606698)
Date: Feb. 28, 2020 · CIK: 0001606698 · Accession: 0000000000-20-001849
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File numbers found in text: 333-23474
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February 28, 2020
Kent Wilson
Chief Executive Officer
Alpine 4 Technologies Ltd.
4742 North 24th Street, Suite 300
Phoenix, AZ 85016
Re:Alpine 4 Technologies Ltd.
Registration Statement on Form S-1 filed February 18, 2020
File No. 333-23474
Dear Mr. Wilson:
We have limited our review of your registration statement to those issues we have
addressed in our 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 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.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-1 filed February 18, 2020
General
1.We note your acquisitions of Excel Fabrication, LLC, Morris Sheet Metal Corp, and
American Precision Fabricators. Please tell us how you considered the guidance in Rules
8-04 and 8-05 of Regulation S-X in assessing whether audited financial statements of
these acquired businesses and the related pro forma financial statements reflecting these
acquisitions should be included in this filing pursuant to Item 11 and provide your
supporting calculations. Alternatively, revise the filing to include the required
information.
2.In a related matter, tell us how you have complied with the requirements of Items 2.01 and
9.01 of Form 8-K as they relate to your acquisitions of Excel Fabrication, LLC, Morris
Sheet Metal Corp, and American Precision Fabricators.
FirstName LastNameKent Wilson
Comapany NameAlpine 4 Technologies Ltd.
February 28, 2020 Page 2
FirstName LastName
Kent Wilson
Alpine 4 Technologies Ltd.
February 28, 2020
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Geoff Kruczek at (202) 551-3641 or Jay Ingram at (202) 551 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing