SEC Comment Letter for Liberated Syndication Inc. (CIK 0001667489) — May 7, 2020
Liberated Syndication Inc. (CIK 0001667489)
Date: May 7, 2020 · CIK: 0001667489 · Accession: 0000000000-20-003982
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File numbers found in text: 000-55779
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United States securities and exchange commission logo
May 6, 2020
Gabriel J. Mosey
Interim Chief Financial Officer
Liberated Syndication Inc.
5001 Baum Blvd, Suite 770
Pittsburgh, PA 15213
Re:Liberated Syndication Inc.
Form 8-K filed May 4, 2020
File No. 000-55779
Dear Mr. Mosey:
We have reviewed your filing 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 8-K filed May 4, 2020
General
1.You disclose that as result of an error, your financial statements as of and for the year
ended, December 31, 2018 should no longer be relied upon. Please explain to us how you
considered the impact of such error on each of the quarterly periods in fiscal 2018 and
2019. To the extent that the error materially impacted any of these periods, revise to also
disclose the quarterly periods that should no longer be relied upon, and tell us how you
intend to correct the previously issued financial statements for such periods.
2.In your Form 10-K/A, you indicate management has concluded that both your disclosure
controls and procedures and internal control over financial reporting were effective as of
December 31, 2018. In light of the restatement to your December 31, 2018 financial
statements, please explain to us how you reached these conclusions. In your response, tell
us the reason for the ineffective disclosure controls and procedures in each of the quarters
during fiscal 2019.
FirstName LastNameGabriel J. Mosey
Comapany NameLiberated Syndication Inc.
May 6, 2020 Page 2
FirstName LastName
Gabriel J. Mosey
Liberated Syndication Inc.
May 6, 2020
Page 2
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.
You may contact David Edgar, Staff Accountant, at (202) 551-3459 if you have questions
regarding our comments. Please contact Kathleen Collins, Accounting Branch Chief, at (202)
551-3499 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology