SEC Comment Letter for Sagoon Inc. (CIK 0001639953) — Jan 17, 2020
Sagoon Inc. (CIK 0001639953)
Date: Jan. 17, 2020 · CIK: 0001639953 · Accession: 0000000000-20-000465
AI Filing Summary & Sentiment
File numbers found in text: 024-11120
Letter
January 17, 2020 Govinda Giri Chief Executive Officer Sagoon Inc. 1980 Teasel Ct. Woodbridge, VA 22192 Re:Sagoon Inc. Amendment No. 1 to Offering Statement on Form 1-A Filed January 6, 2020 File No. 024-11120 Dear Mr. Giri: We have reviewed your amended offering statement and 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 this letter by amending your offering 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 offering statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 12, 2019 letter. Amendment No. 1 to Offering Statement on Form 1-A The Company's Business, page 18 1.Your revised disclosure in response to prior comment 3 appears to measure users on a cumulative basis. In this regard, you state that the number of users increased to 4,382,960 in 2019 although the monthly numbers in the chart on page 18 indicate that approximately one million users visited the company's site in 2019. Please clarify that the user metric used throughout the filing represents any user who has ever used the company's site since inception. Further, discuss any limitations, risks, and challenges regarding your ability to accurately account for user activity. Refer to prior comment 3 and disclose whether you are able to distinguish unique users or active users on your platform.
FirstName LastNameGovinda Giri Comapany NameSagoon Inc. January 17, 2020 Page 2 FirstName LastName Govinda Giri Sagoon Inc. January 17, 2020 Page 2 You may contact Ryan Rohn, Staff Accountant, at (202) 551-3739 or Stephen Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding comments on the financial statements and related matters. Please contact Bernard Nolan, Attorney-Adviser, at (202) 551-6515 or, in his absence, Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Andrew Stephenson
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January 17, 2020
Govinda Giri
Chief Executive Officer
Sagoon Inc.
1980 Teasel Ct.
Woodbridge, VA 22192
Re:Sagoon Inc.
Amendment No. 1 to Offering Statement on Form 1-A
Filed January 6, 2020
File No. 024-11120
Dear Mr. Giri:
We have reviewed your amended offering statement and 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 this letter by amending your offering 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 offering statement and the information you
provide in response to these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our December 12, 2019 letter.
Amendment No. 1 to Offering Statement on Form 1-A
The Company's Business, page 18
1.Your revised disclosure in response to prior comment 3 appears to measure users on a
cumulative basis. In this regard, you state that the number of users increased to 4,382,960
in 2019 although the monthly numbers in the chart on page 18 indicate that approximately
one million users visited the company's site in 2019. Please clarify that the user metric
used throughout the filing represents any user who has ever used the company's site since
inception. Further, discuss any limitations, risks, and challenges regarding your ability to
accurately account for user activity. Refer to prior comment 3 and disclose whether you
are able to distinguish unique users or active users on your platform.
FirstName LastNameGovinda Giri
Comapany NameSagoon Inc.
January 17, 2020 Page 2
FirstName LastName
Govinda Giri
Sagoon Inc.
January 17, 2020
Page 2
You may contact Ryan Rohn, Staff Accountant, at (202) 551-3739 or Stephen Krikorian,
Accounting Branch Chief, at (202) 551-3488 if you have questions regarding comments on the
financial statements and related matters. Please contact Bernard Nolan, Attorney-Adviser, at
(202) 551-6515 or, in his absence, Jan Woo, Legal Branch Chief, at (202) 551-3453 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Andrew Stephenson