SEC Comment Letter for GD Culture Group Ltd (GDC) (CIK 0001641398) (GDC) — Jan 22, 2018

GD Culture Group Ltd (GDC) (CIK 0001641398)
Date: Jan. 22, 2018 · CIK: 0001641398 · Accession: 0000000000-18-002203

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AI Filing Summary & Sentiment

Sentiment

Urgency

Document Type

Confidence

SEC Posture

Company Posture

Summary

Reasoning

Date

January 22, 2018

Author

/s/ Pamela A. Long

Form

UPLOAD

Company

GD Culture Group Ltd (GDC) (CIK 0001641398)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 -4631 DIVISION OF CORPORATION FINANCE Mail Stop 4631 January 22, 2018 Via E-Mail Mr. Tim Richerson Chief Executive Officer JM Global Holding Company 1615 South Congress Avenue, Suite 103 Delray Beach, FL 33445

Re: JM Global Holding Company Preliminary Merger Proxy Statement on Schedule 14A Filed October 11, 2017 File No. 1 -37513

Dear Mr. Richerson :

We have completed our review of your filing. 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.

Very truly yours,
/s/ Pamela A. Long

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4631
       DIVISION OF
CORPORATION FINANCE

 Mail Stop 4631

       January 22, 2018

Via E-Mail
Mr. Tim Richerson
Chief Executive Officer
JM Global Holding Company
1615 South Congress Avenue, Suite 103
Delray Beach, FL 33445

 Re: JM Global Holding Company
  Preliminary Merger Proxy Statement on Schedule 14A
  Filed October 11, 2017
 File No. 1 -37513

Dear Mr. Richerson :

We have completed our review of your filing.  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.

       Very truly yours,

       /s/ Pamela A. Long

       Pamela A. Long
       Assistant Director
       Office of Manufacturing an d Construction

cc: Via E-Mail
 Douglas Ellenoff , Esq.
 Stuart Neuhauser, Esq.
 Ellenoff Grossman & Schole LLP
 1345 Avenue of the Americas, 11th Floor
 New York, NY 10105

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