SEC Company Response from Sagoon Inc. (CIK 0001639953) — Jan 31, 2020
Sagoon Inc. (CIK 0001639953)
Date: Jan. 31, 2020 · CIK: 0001639953 · Accession: 0001104659-20-008945
AI Filing Summary & Sentiment
File numbers found in text: 024-11120
Referenced dates: December 12, 2019, January 29, 2020
Letter
Division of Corporation Finance Office of Technology United States Securities and Exchange Commission Amendment No. 2 to Offering Statement on Form 1-A Filed January 22, 2020 Response dated January 29, 2020 File No. 024-11120
Re:
Dear Mr. Nolan and Ms. Nicholson,
Thank you for your comments dated January 29, 2020 regarding the Offering Statement of Sagoon, Inc. (the “Company”). We appreciate the opportunity to respond to your comments, which we have set out below together with the Company’s responses.
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.”
The Company has amended its disclosure regarding user metrics to clarify that it is identifying new users rather than active users, and the methods used to measure those users. In addition, the Company removed the statement “[h]undreds of thousands of people visit your site on a monthly basis.”
Thank you again for the opportunity to respond to your questions to the Offering Statement of the Company. If you have additional questions or comments, please contact me at andrew@crowdchecklaw.com.
Sincerely,
/s/ Andrew Stephenson
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CORRESP
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Bernard Nolan, Attorney-Advisor
Jan Woo, Legal Branch Chief
Division of Corporation Finance
Office of Technology
United States Securities and Exchange Commission
Washington, D.C. 20549
January 31, 2020
Re:
Sagoon, Inc.
Amendment No. 2 to Offering Statement on Form 1-A
Filed January 22, 2020
Response dated January 29, 2020
File No. 024-11120
Dear Mr. Nolan and Ms. Nicholson,
Thank you for your comments dated January
29, 2020 regarding the Offering Statement of Sagoon, Inc. (the “Company”). We appreciate the opportunity to respond
to your comments, which we have set out below together with the Company’s responses.
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.”
The Company has amended its disclosure regarding
user metrics to clarify that it is identifying new users rather than active users, and the methods used to measure those users.
In addition, the Company removed the statement “[h]undreds of thousands of people visit your site on a monthly basis.”
Thank you again for the opportunity to respond to your questions
to the Offering Statement of the Company. If you have additional questions or comments, please contact me at andrew@crowdchecklaw.com.
Sincerely,
/s/ Andrew Stephenson
Andrew Stephenson
Partner
CrowdCheck Law, LLP
cc: Govinda Giri
Chief Executive Officer Sagoon Inc.
1980 Teasel Ct.
Woodbridge, VA 22192