SEC Comment Letter for UPAY (UPYY) (CIK 0001677897) (UPYY) — Nov 14, 2019
UPAY (UPYY) (CIK 0001677897)
Date: Nov. 14, 2019 · CIK: 0001677897 · Accession: 0000000000-19-015505
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File numbers found in text: 333-234566
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November 14, 2019
Wouter A. Fouche
Chief Executive Officer
UPAY, Inc.
3010 LBJ Freeway, 12th Floor
Dallas, Texas 75234
Re:UPAY, Inc.
Registration Statement on Form S-1
Filed November 7, 2019
File No. 333-234566
Dear Mr. Fouche:
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rule 461 regarding requests for acceleration. 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.
Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or, in his absence, Jan
Woo, Legal Branch Chief, at (202) 551-3453 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Frederick M. Lehrer, Esq.