SEC Company Response from Onar Holding Corp (ONAR) (CIK 0001682265) (ONAR) — Jan 30, 2017
Onar Holding Corp (ONAR) (CIK 0001682265)
Date: Jan. 30, 2017 · CIK: 0001682265 · Accession: 0001580695-17-000076
AI Filing Summary & Sentiment
File numbers found in text: 333-214274
Referenced dates: January 11, 2017, January 23, 2017
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CORRESP
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January 30, 2017
Ms. Pamela Long
Assistant Director
Office of Manufacturing and Construction
U.S. Securities and Exchange Commission
Mail Stop 4631
Division of Corporate Finance
Washington, D.C. 20549
Re:
Reliant Holdings, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed January 13, 2017
File No. 333-214274
Dear Ms. Long:
On behalf of Reliant Holdings,
Inc., a Nevada corporation (the “Company”), we are providing the staff (the “Staff”) of the
Securities and Exchange Commission (the “Commission”) the below responses to the Staff’s comment letter
dated January 23, 2017, relating to the Company’s Registration Statement on Form S-1/A Amendment No. 2 (File No. 333-214274)
(the “Registration Statement”) filed with the Commission on January 13, 2017, in connection with the registration
for resale of 3,585,000 shares of the Company’s common stock (“Common Stock”) by the selling stockholders
named in the Registration Statement (collectively, the “Selling Stockholders”).
In connection with these
responses the Company is filing an Amendment No. 3 to the Registration Statement on Form S-1 (“Amendment No. 3”)
via EDGAR.
The Company’s responses
to the Staff’s comments are indicated below, directly following a restatement of each comment in bold type.
Ms. Pamela Long
January 30, 2017
Page 2 of 2
Management’s Discussion and Analysis
of Financial Condition . . ., page 40
1. We
note your response to comment 4 in our letter dated January 11, 2017 and we re-issue our comment. Please revise your disclosure
throughout this section to discuss the specific reasons for the changes in your operating results so that potential investors gain
better insight into your results, particularly for trend purposes and discerning future prospects.
RESPONSE:
The Company has updated
its discussions and descriptions under Results of Operations in Amendment No. 3 to discuss the specific reasons for the changes
in its operating results as you have requested and has expanded significantly its descriptions for material line items, costs of
sales, and the reasons for the changes in revenue, period-over-period.
Yours very truly,
/s/ John S. Gillies
John S. Gillies
Senior Associate