SEC Comment Letter for Connexa Sports Technologies Inc. (YYAI) (CIK 0001674440) (YYAI) — Feb 13, 2017
Connexa Sports Technologies Inc. (YYAI) (CIK 0001674440)
Date: Feb. 13, 2017 · CIK: 0001674440 · Accession: 0000000000-17-005034
AI Filing Summary & Sentiment
Letter
Mail Stop 3720 February 13, 2017 Iuliia Gitelman President Lazex Inc. 68/29 Husitska St. Zizkov, Prague Czech Republic 13000
Re: Lazex Inc. Amendment No. 1 to Registration Statement on Form S -1 Filed February 3, 2017 File No. 333 -214463
Dear Ms. Gitelman:
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 believe an amendment is a ppropriate, 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 December 2, 2016 letter .
General
1. We note your response to our comment 1 and continue to believe that you meet the definition of a shell company. Please describe in greater detail the “various other activities” you have undertaken with respect to your operations. To the extent you are able to provide us with information detailing your substantive operations —beyond your investigation of market demand and preliminary negotiations with potential customers — please do so. We note the disclosure in your registration statement that you do not have sufficient capital to commence operations .
You may contact Christie Wong, Staff Accountant, at (202) 551 -3684 or Ivette Leon, Assistant Chief Accountant, at (202) 551 -3351 if you have questions regarding comments on the
Iuliia Gitelman Lazex Inc. February 13, 2017 Page 2
financial statements and related matters. Please contact Joshua Shainess, Attorney -Adviser, at (202) 551 -7951, Celeste M. Murphy, Legal Branch Chief, at (202) 551 -3257, or me at (202) 551 - 3810 with any other quest ions.
Sincerely,
/s/ Celeste M. Murphy for
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Mail Stop 3720 February 13, 2017 Iuliia Gitelman President Lazex Inc. 68/29 Husitska St. Zizkov, Prague Czech Republic 13000 Re: Lazex Inc. Amendment No. 1 to Registration Statement on Form S -1 Filed February 3, 2017 File No. 333 -214463 Dear Ms. Gitelman: 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 believe an amendment is a ppropriate, 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 December 2, 2016 letter . General 1. We note your response to our comment 1 and continue to believe that you meet the definition of a shell company. Please describe in greater detail the “various other activities” you have undertaken with respect to your operations. To the extent you are able to provide us with information detailing your substantive operations —beyond your investigation of market demand and preliminary negotiations with potential customers — please do so. We note the disclosure in your registration statement that you do not have sufficient capital to commence operations . You may contact Christie Wong, Staff Accountant, at (202) 551 -3684 or Ivette Leon, Assistant Chief Accountant, at (202) 551 -3351 if you have questions regarding comments on the Iuliia Gitelman Lazex Inc. February 13, 2017 Page 2 financial statements and related matters. Please contact Joshua Shainess, Attorney -Adviser, at (202) 551 -7951, Celeste M. Murphy, Legal Branch Chief, at (202) 551 -3257, or me at (202) 551 - 3810 with any other quest ions. Sincerely, /s/ Celeste M. Murphy for Larry Spirgel Assistant Director AD Office 11 – Telecommunications