SEC Comment Letter for Sagoon Inc. (CIK 0001639953) — Jan 30, 2020
Sagoon Inc. (CIK 0001639953)
Date: Jan. 30, 2020 · CIK: 0001639953 · Accession: 0000000000-20-000793
AI Filing Summary & Sentiment
File numbers found in text: 024-11120
Referenced dates: December 12, 2019
Letter
January 29, 2020 Govinda Giri Chief Executive Officer Sagoon Inc. 1980 Teasel Ct. Woodbridge, VA 22192 Re:Sagoon Inc. Amendment No. 2 to Offering Statement on Form 1-A Filed January 22, 2020 File No. 024-11120 Dear Mr. Giri: We have reviewed your amended offering statement and have the following comment. In our comment, 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 comment applies 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 this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our January 17, 2020 letter. Amendment No. 2 to Offering Statement on Form 1-A The Company's Business, page 18 1.Your revised disclosure in response to the prior comment and to comment 3 of our letter dated December 12, 2019 does not quantify active users of your platform for each period presented. As it appears that there is a measure of user activity that you use in managing your business (e.g., average monthly active users), please provide such information in addition to the registered user information that you provide, or advise. In this regard, we note your statement that "[h]undreds of thousands of people visit your site on a monthly basis."
FirstName LastNameGovinda Giri Comapany NameSagoon Inc. January 29, 2020 Page 2 FirstName LastName Govinda Giri Sagoon Inc. January 29, 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 29, 2020
Govinda Giri
Chief Executive Officer
Sagoon Inc.
1980 Teasel Ct.
Woodbridge, VA 22192
Re:Sagoon Inc.
Amendment No. 2 to Offering Statement on Form 1-A
Filed January 22, 2020
File No. 024-11120
Dear Mr. Giri:
We have reviewed your amended offering statement and have the following comment. In
our comment, 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 comment applies 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 this comment, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our January 17, 2020 letter.
Amendment No. 2 to Offering Statement on Form 1-A
The Company's Business, page 18
1.Your revised disclosure in response to the prior comment and to comment 3 of our letter
dated December 12, 2019 does not quantify active users of your platform for each period
presented. As it appears that there is a measure of user activity that you use in managing
your business (e.g., average monthly active users), please provide such information in
addition to the registered user information that you provide, or advise. In this regard, we
note your statement that "[h]undreds of thousands of people visit your site on a monthly
basis."
FirstName LastNameGovinda Giri
Comapany NameSagoon Inc.
January 29, 2020 Page 2
FirstName LastName
Govinda Giri
Sagoon Inc.
January 29, 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