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SEC Comment Letter for Jingbo Technology, Inc. (SVMB) (CIK 0001647822) (SVMB) — Nov 13, 2015

Jingbo Technology, Inc. (SVMB) (CIK 0001647822)
Date: Nov. 13, 2015 · CIK: 0001647822 · Accession: 0000000000-15-053986

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
November 13, 2015
Author
/s/ Mark P. Shuman
Form
UPLOAD
Company
Jingbo Technology, Inc. (SVMB) (CIK 0001647822)

Letter

Mail Stop 4561 November 13, 2015 Lakhwinder Singh Sidhu, President SavMobi Technology Inc. 73B Bank Avenue Amritsar, Punjab, 143001 India

Re: SavMobi Technology Inc. Amendment No. 1 to Registration Statement on Form S -1 Filed October 30, 2015 File No. 333 -206804

Dear Mr. Sidhu:

We have reviewed your amended registration 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 registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstances or do not bel ieve an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your registration 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 October 2, 2015 letter .

Risk Factors, page 9

1. We reissue prior comment 7 in part, insofar as you have not disclosed here and in Capital Resources and Liquidity, the minimum number of months that yo u will be able to conduct your planned operations using currently available capital resources .

Description of Business, page 22

2. We note your response to prior comment 2. However, please further revise your disclosure to explain that the market data presented in this section represents calculations you have made based on underlying data contained in the Borrell Associates report, rather than data points actually contained in the reports.

Lakhwinder Singh Sidhu SavMobi Technology Inc. November 13, 2015 Page 2

3. We note your response to pri or comment 4. However, your disclosure on page 23, states that “ the tot al software development cost [is] $38,000. ” Elsewhere in your filing you state that you requ ire a minimum of $25,000 of gross off ering proceeds, to implement your business plan. Please revise to ensure your capital needs are stated consistently, or tell us why you believe that the existing disclosure s consistently state such needs.

Competition , page 25

4. You state that Yelp and Pirq are your biggest competitors . This disclosure suggest s that you are currently operating in this business space. Since you have yet to launch your mobile solution, it appears that you should revise this statement to reflect that you expect these companies to be competitors in the future.

5. We note your response to prior comment 14. Please further revise your disclosures to describe whether the features you intend to include in your software, that you describe in the ultimate paragraph of page 25, are already included other apps or software.

Business Experience, page 31

6. We note that the biographica l information for your director and officer has a promotional tone. Please revise to limit the information to factually verifiable statements.

7. We note y our response to prior comment 6; however, we are unable to concur with your assertion that this information is not required to be disclosed pursuant to Item 401 of Regulation S -K.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accu racy and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date of the pending regist ration statement, please provide a written statement from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

Lakhwinder Singh Sidhu SavMobi Technology Inc. November 13, 2015 Page 3

 the company may not assert staff comments and the declaration of effec tiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for acceleration . We will consider a written request for accel eration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relat e to the proposed public offering of the securities specified in the above registration statement. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.

You may contact Morgan Youngwood, Staff Accountant, at (202) 551 -3479, or Stephen Krikorian, Accounting Branch Chief, at (202) 551 -3488, if you have any questions regarding comments on the financial statements and other related matters. If you have any ot her questions, please contact Ivan Griswold, Attorney -Advisor, at (202) 551 -3853 or in his absence, me at (202) 551 -3462. If you require further assistance, please contact Barbara C. Jacobs, Assistant Director, at (202) 551 -3730.

Sincerely,
/s/ Mark P. Shuman

Show Raw Text
Mail Stop 4561
  November 13, 2015

Lakhwinder Singh Sidhu, President
SavMobi Technology Inc.
73B Bank Avenue
Amritsar, Punjab, 143001
India

Re: SavMobi Technology Inc.
Amendment No. 1 to Registration Statement on Form S -1
Filed October 30, 2015
  File No. 333 -206804

Dear Mr. Sidhu:

We have reviewed your amended registration 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 registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not bel ieve an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration 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 October 2, 2015 letter .

Risk Factors, page 9

1. We reissue prior comment 7 in part, insofar as you have not disclosed here and in Capital
Resources and Liquidity, the minimum number of months that yo u will be able to
conduct your planned operations using currently available capital resources .

Description of Business, page 22

2. We note your response to prior comment 2.  However, please further revise your
disclosure to explain that the market data presented in this section represents calculations
you have made based on underlying data contained in the Borrell Associates report,
rather than data points actually contained in the reports.

Lakhwinder Singh Sidhu
SavMobi Technology Inc.
November 13, 2015
Page 2

 3. We note your response to pri or comment 4.  However, your disclosure on page 23, states
that “ the tot al software development cost [is] $38,000. ”  Elsewhere in your filing you
state that you requ ire a minimum of $25,000 of gross off ering proceeds, to implement
your business plan.   Please revise to ensure your capital needs are stated consistently, or
tell us why you believe that the existing disclosure s consistently state such needs.

Competition , page 25

4. You state that Yelp and Pirq are your biggest competitors .  This disclosure suggest s that
you are currently operating in this business space.   Since you have yet to launch your
mobile solution, it appears that you should revise this statement to  reflect that you expect
these companies to be competitors in the future.

5. We note your response to prior comment 14.  Please further revise your disclosures to
describe whether the features you intend to include in your software, that you describe in
the ultimate paragraph of page 25, are already included other apps or software.

Business Experience, page 31

6. We note that the biographica l information for your director and officer  has a promotional
tone.  Please revise to limit the information to factually verifiable statements.

7. We note y our response to prior comment 6;  however,  we are unable to concur with your
assertion that this information is not required to be disclosed pursuant to Item 401 of
Regulation S -K.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain  that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accu racy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending regist ration statement, please provide  a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant  to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

Lakhwinder Singh Sidhu
SavMobi Technology Inc.
November 13, 2015
Page 3

  the company may not assert staff comments and the declaration of effec tiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for accel eration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relat e to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

You may contact Morgan Youngwood, Staff Accountant, at (202) 551 -3479, or Stephen
Krikorian, Accounting Branch Chief, at (202) 551 -3488, if you have any questions regarding
comments on the financial statements and other related matters.  If you have any ot her questions,
please contact Ivan Griswold, Attorney -Advisor, at (202) 551 -3853 or in his absence, me at
(202) 551 -3462.  If you require further assistance, please contact Barbara C. Jacobs, Assistant
Director, at (202) 551 -3730.

        Sincerely,

        /s/ Mark P. Shuman

        Mark P. Shuman
        Branch Chief - Legal
Office of Information
Technologies and Services

cc:  Andrew Befumo, Esq.
 Befumo and Schaeffer, PLC