SEC Company Response from Onar Holding Corp (ONAR) (CIK 0001682265) (ONAR) — Aug 9, 2017
Onar Holding Corp (ONAR) (CIK 0001682265)
Date: Aug. 9, 2017 · CIK: 0001682265 · Accession: 0001580695-17-000341
AI Filing Summary & Sentiment
File numbers found in text: 333-214274
Referenced dates: August 4, 2017
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CORRESP
1
filename1.htm
August 9, 2017
Mr. Jay Ingram
Legal Branch Chief
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. 5 to Registration Statement on Form S-1
Filed July 25, 2017
File No. 333-214274
Dear Mr. Ingram:
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 August 4, 2017, relating to the Company’s Registration Statement on Form S-1/A Amendment No. 5 (File No. 333-214274)
(the “Registration Statement”) filed with the Commission on July 25, 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. 6 to the Registration Statement on Form S-1 (“Amendment No. 6”)
via EDGAR.
The Company’s
responses to the Staff’s comments are indicated below, directly following a restatement of each comment in bold type.
Plan of Operations, page 2
1.
You state that
with your current cash on hand, expected revenues and based on your current average monthly expenses that you do not anticipate
the need for any additional funds for approximately the next 12 months. However, you also disclose that you anticipate requiring
$200,000 to fund your operations over the next twelve months and based on your disclosure it appears the source of some of the
funding is external. Given this, it appears that you will need additional funding for the next 12 months. Please amend your filing
to clarify. Additionally, we note that your “Plan of Operations” disclosure on page 39 appears to contradict your
liquidity needs under the same heading on page 2. Please revise to correct.
RESPONSE:
The disclosures in the amended registration
statement have been updated and clarified to address your comment.
Mr. Jay Ingram
August 9, 2017
Page 2 of 2
Summary Financial Data, page 5
2.
Please amend
your filing to present financial data for the audited 2 years ended December 31, 2016, and comparative 3 months ended March 31,
2017. Refer to Item 301(d) of Regulation S-K for guidance. Also, please refer to Instructions 1 and 2 to Item 301 regarding the
presentation and the items to be included in the table. While you may include additional items under Instruction 2 that you believe
useful, reproduction of the entirety of the balance sheets and statements of operations appears contrary to the purpose of summary
financial data.
RESPONSE:
The Company has updated the amended
Registration Statement to address your comment, to update the summary financial data presented therein, and to only include information
the Company believes is useful and not a reproduction of the entirety of such financial information.
Yours very truly,
/s/ John S. Gillies
John S. Gillies
Senior Associate