SEC Company Response from Legion Capital Corp (LGCP) (CIK 0001661166) — Feb 21, 2020

Legion Capital Corp (LGCP) (CIK 0001661166)
Date: Feb. 21, 2020 · CIK: 0001661166 · Accession: 0001213900-20-004528

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File numbers found in text: 024-11123

Date

February 21, 2020

Author

/s/ James S. Byrd, Jr.

Form

CORRESP

Company

Legion Capital Corp (LGCP) (CIK 0001661166)

Letter

Mr. Michael Volley Mr. Amit Pande Re: Legion Capital Corporation Form 1-A filing – Request for Qualification File No. 024-11123

Dear Ms. and Messrs. Livingston, Clampitt, Volley and Pande,

On behalf of Legion Capital Corporation (the “Company”), I hereby request qualification of the above-referenced offering statement at 5:00 p.m., Eastern Time, on Wednesday February 26, 2020, or as soon thereafter as is practicable.

In making this request, the Company acknowledges that:

Should the Commission or the staff, acting pursuant to delegated authority, qualify the filing, 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 qualifying the filing, does not relieve the Company from its full responsibility from the adequacy and accuracy of the disclosure in the filing; and

The Company may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very Truly Yours,
/s/ James S. Byrd, Jr.

Show Raw Text

CORRESP
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filename1.htm

Legion Capital Corporation

301 E. Pine St., Ste. 850

Orlando, Fl. 32801

(407) 986-4234

February 21, 2020

AMENDED REQUEST FOR QUALIFICATION

Ms. Jessica Livingston

Mr. Michael Clampitt

Mr. Michael Volley

Mr. Amit Pande

Re: Legion Capital Corporation Form 1-A filing – Request for
Qualification

File No. 024-11123

Dear Ms. and Messrs. Livingston, Clampitt,
Volley and Pande,

On behalf of Legion Capital
Corporation (the “Company”), I hereby request qualification of the above-referenced offering statement at 5:00 p.m.,
Eastern Time, on Wednesday February 26, 2020, or as soon thereafter as is practicable.

In making this request, the Company acknowledges
that:

    ·

    Should the Commission or the staff, acting pursuant to delegated authority,
qualify the filing, 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 qualifying the filing, does not relieve the Company from its full responsibility from the adequacy and accuracy of
the disclosure in the filing; and

    ·

    The Company may not assert staff comments and/or qualification as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

    Very Truly Yours,

    /s/ James S. Byrd, Jr.

    James S. Byrd, Jr.

        Chairman
and CEO

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