SEC Company Response from Sagoon Inc. (CIK 0001639953) — Mar 16, 2021
Sagoon Inc. (CIK 0001639953)
Date: March 16, 2021 · CIK: 0001639953 · Accession: 0001104659-21-037328
AI Filing Summary & Sentiment
File numbers found in text: 024-11120
Referenced dates: March 16, 2021
Letter
Office of Technology Division of Corporation Finance Sagoon, Inc. Offering Statement on Form 1-A POS Response dated March 16, 2021 File No. 024-11120
Re:
Dear Mr. Spirgel,
Thank you for your comments dated March 16, 2021 regarding the Offering Statement on Form 1-A POS 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.
Post-Qualification Amendment No. 1 to Offering Statement on Form 1-A
Security Ownership of Management and Certain Securityholders, page 24
1. We note that during the year ended December 31, 2019, an investor exercised warrants to purchase 15,217 shares of Class C common stock. Please update the voting security ownership table to identify any securityholder who beneficially owns more than 10% of any class of your voting securities. See Item 12 of Form 1-A.
The Company confirms that there are no securityholders who beneficially own more than 10% of the Class C Common Stock, a voting security. Further, the Company has updated the table on page 24 to confirm that there are no securityholders who beneficially own more than 10% of the Class C Common Stock.
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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filename1.htm
Mr. Larry Spirgel
Office Chief
Office of Technology
Division of Corporation Finance
US Securities and Exchange Commission
Washington, D.C. 20549
March 16, 2021
Re:
Sagoon, Inc.
Offering Statement on Form 1-A POS
Response dated March 16, 2021
File No. 024-11120
Dear Mr. Spirgel,
Thank you for your comments dated March 16, 2021 regarding the
Offering Statement on Form 1-A POS 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.
Post-Qualification Amendment No. 1 to Offering Statement
on Form 1-A
Security Ownership of Management and Certain Securityholders,
page 24
1. We note that during the year ended December 31, 2019, an investor exercised warrants to purchase 15,217 shares of Class C common
stock. Please update the voting security ownership table to identify any securityholder who beneficially owns more than 10% of
any class of your voting securities. See Item 12 of Form 1-A.
The Company confirms that there are no securityholders
who beneficially own more than 10% of the Class C Common Stock, a voting security. Further, the Company has updated the table on
page 24 to confirm that there are no securityholders who beneficially own more than 10% of the Class C Common Stock.
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