Correspondence 0001575872-24-000882 from EOS INC. (CIK 0001651958)
EOS INC. (CIK 0001651958)
Date: Aug. 7, 2024 · CIK: 0001651958 · Accession: 0001575872-24-000882
AI Filing Summary & Sentiment
File numbers found in text: 000-55661
Letter
THE VERONA FIRM PLLC (813) 258-0852
P.O. Box 18191 brett@theveronafirm.com
Tampa, Florida 33679 TheVeronaFirm.com
August 6, 2024
Mr. Nicholas O’Leary
US Securities and Exchange Commission
Division of Corporation Finance
Office of Industrial Applications and Services
Washington, D.C. 20549
RE: EOS, Inc., Amendment No. 1 to Form 10-K for Fiscal Year Ended December 31, 2023 File No. 000-55661
Mr. O’Leary:
Below please find our response to your questions and comments posed in your correspondence of July 24, 2024. We have revised the 10-K and will be uploading it accordingly.
1. We note your disclosure that a portion of your operations are in Hong Kong, your management has members based in China and Hong Kong, and you have a principal distributor in Hong Kong. We also note that your recently filed 10-Q shows that 96% of your revenue is attributable to Hong Kong for the three months ended March 31, 2024. Please review the Division of Corporation Finance's December 20, 2021, guidance "Sample Letter to China-Based Companies" available at https://www.sec.gov/corpfin/sample-letter-china-based-companies and provide us with an analysis of whether you have the majority of your operations in China, which includes Hong Kong. If so, please update your disclosure to fully discuss the legal and operational risks associated with being a China-based company, or explain why such comments are not applicable to the company.
Response: We have revised the filing to include additional Risk Factors reflecting the fact of the company having significant business in Hong Kong and management in both Hong Kong and China.
2. We note your response to comment 1. Please revise the document throughout to clarify which individual is your Chief Financial Officer and provide the associated disclosure. It is unclear when Mr. Zongjiang He became your Chief Financial Officer, however, we note you have not provided his information in Part III of the Form 10-K, and he did not sign the amended Form 10-K as your Principal Financial Officer. Please revise or advise.
Response: We have revised the filing to reflect Mr. Zongjiang He who is the Chief Financial Officer, and have provided his information in Part III of the revised filing.
Additionally, the address listed on pages 9 and 29 has been updated to correspond with the address otherwise listed.
If you have any questions, or need anything further, please do not hesitate to contact me.
Kind regards.
Brett Verona
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THE VERONA FIRM PLLC
(813) 258-0852
P.O. Box 18191
brett@theveronafirm.com
Tampa, Florida 33679
TheVeronaFirm.com
August 6, 2024
Mr. Nicholas O’Leary
US Securities and Exchange Commission
Division of Corporation Finance
Office of Industrial Applications and Services
Washington, D.C. 20549
RE: EOS, Inc., Amendment No. 1 to Form 10-K
for Fiscal Year Ended December 31, 2023 File No. 000-55661
Mr. O’Leary:
Below please find our response to your questions
and comments posed in your correspondence of July 24, 2024. We have revised the 10-K and will be uploading it accordingly.
1. We
note your disclosure that a portion of your operations are in Hong Kong, your management has members based in China and Hong Kong, and
you have a principal distributor in Hong Kong. We also note that your recently filed 10-Q shows that 96% of your revenue is attributable
to Hong Kong for the three months ended March 31, 2024. Please review the Division of Corporation Finance's December 20, 2021, guidance
"Sample Letter to China-Based Companies" available at https://www.sec.gov/corpfin/sample-letter-china-based-companies
and provide us with an analysis of whether you have the majority of your operations in China, which includes Hong Kong. If so, please
update your disclosure to fully discuss the legal and operational risks associated with being a China-based company, or explain why such
comments are not applicable to the company.
Response: We have revised
the filing to include additional Risk Factors reflecting the fact of the company having significant business in Hong Kong and management
in both Hong Kong and China.
2. We
note your response to comment 1. Please revise the document throughout to clarify which individual is your Chief Financial Officer and
provide the associated disclosure. It is unclear when Mr. Zongjiang He became your Chief Financial Officer, however, we note you have
not provided his information in Part III of the Form 10-K, and he did not sign the amended Form 10-K as your Principal Financial Officer.
Please revise or advise.
Response: We have revised
the filing to reflect Mr. Zongjiang He who is the Chief Financial Officer, and have provided his information in Part III of the revised
filing.
Additionally, the address listed on pages 9 and
29 has been updated to correspond with the address otherwise listed.
If you have any questions, or need anything further,
please do not hesitate to contact me.
Kind regards.
Brett Verona