SEC Comment Letter 0000000000-24-012712 to SMART RX SYSTEMS INC (CIK 0001672227)
SMART RX SYSTEMS INC (CIK 0001672227)
Date: Nov. 18, 2024 · CIK: 0001672227 · Accession: 0000000000-24-012712
AI Filing Summary & Sentiment
File numbers found in text: 024-12426
Letter
November 18, 2024 Santu Rohatgi Chairman of the Board and President Smart Rx Systems, Inc. 18540 N. Dale Mabry Highway, Lutz, Florida 33548 Re:Smart Rx Systems, Inc. Amendment No. 1 to Offering Statement on Form 1-A Filed October 24, 2024 File No. 024-12426 Dear Santu Rohatgi: We have reviewed your amended offering statement and have the following comment(s). Please respond to this letter by amending your offering statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your offering statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our May 13, 2024 letter. Amendment No. 1 to Offering Statement on Form 1-A filed October 24, 2024 Management's Discussion and Analysis of Financial Condition and Results of Operations, page 54 We note your response to prior comment 5, as well as your revised financial statements that include the financials for your fiscal year ending December 31, 2023 and the six months ending June 30, 2024. We reissue the comment in-part. Please update your Management's Discussion and Analysis of Financial Condition and Results of Operation in accordance with Item 9 of Form 1-A, as well as throughout the offering circular as appropriate. As examples only, we note that your discussion of operating results does not appear to reflect your results as of June 30, 2024, you do not discuss the extent of your financial condition for 2023, and you do not discuss changes in financial condition and results of operations between 2023 and 2022 or 1.
November 18, 2024 Page 2 between June 30, 2024 and June 30, 2023, including the causes of material changes from year to year or period to period. Please contact Brian Fetterolf at 202-551-6613 or Lilyanna Peyser at 202-551-3222 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc:Thomas Voekler
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November 18, 2024
Santu Rohatgi
Chairman of the Board and President
Smart Rx Systems, Inc.
18540 N. Dale Mabry Highway,
Lutz, Florida 33548
Re:Smart Rx Systems, Inc.
Amendment No. 1 to Offering Statement on Form 1-A
Filed October 24, 2024
File No. 024-12426
Dear Santu Rohatgi:
We have reviewed your amended offering statement and have the following
comment(s).
Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your offering statement and the information you
provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our May 13, 2024 letter.
Amendment No. 1 to Offering Statement on Form 1-A filed October 24, 2024
Management's Discussion and Analysis of Financial Condition and Results of Operations,
page 54
We note your response to prior comment 5, as well as your revised financial
statements that include the financials for your fiscal year ending December 31, 2023
and the six months ending June 30, 2024. We reissue the comment in-part. Please
update your Management's Discussion and Analysis of Financial Condition and
Results of Operation in accordance with Item 9 of Form 1-A, as well as throughout
the offering circular as appropriate. As examples only, we note that your discussion of
operating results does not appear to reflect your results as of June 30, 2024, you do
not discuss the extent of your financial condition for 2023, and you do not discuss
changes in financial condition and results of operations between 2023 and 2022 or 1.
November 18, 2024
Page 2
between June 30, 2024 and June 30, 2023, including the causes of material changes
from year to year or period to period.
Please contact Brian Fetterolf at 202-551-6613 or Lilyanna Peyser at 202-551-3222
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Thomas Voekler