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SEC Comment Letter for EDISON NATION, INC. (BBIG) (CIK 0001717556) — Aug 15, 2022

EDISON NATION, INC. (BBIG) (CIK 0001717556)
Date: Aug. 15, 2022 · CIK: 0001717556 · Accession: 0000000000-22-008690

AI Filing Summary & Sentiment

File numbers found in text: 001-38448

Date
August 15, 2022
Author
Not clearly detected
Form
UPLOAD
Company
EDISON NATION, INC. (BBIG) (CIK 0001717556)

Letter

United States securities and exchange commission logo August 15, 2022 Philip Jones Chief Financial Officer Vinco Ventures, Inc. 6 North Main Street Fairport, New York 14450 Re:Vinco Ventures, Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed April 15, 2022 File No. 001-38448 Dear Mr. Jones: We have limited our review of your filing to the financial statements and related disclosures 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 these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2021 Business , page 4 1.We note your disclosure on page 5 that your wholly-owned subsidiary EVNT Platform LLC, dba Emmersive Entertainment ("EVNT"), offers a streaming music Non-Fungible Token ("NFT") platform that generates revenue "from the development of custom, digital artwork and digital music that is sold in the form of non-fungible tokens through a third- party marketplace." We also note your disclosure on page 87 that your asset acquisition from Emmersive Entertainment, Inc. included "digital assets." Please address the following comments related to your digital assets:

•Tell us and disclose your accounting policies related to digital assets, including NFT's. Ensure your response addresses, but is not necessarily limited to, the specific nature of the digital assets recorded on your balance sheet, how you record digital assets upon initial recognition, how you account for them after initial recognition, and

FirstName LastNamePhilip Jones Comapany NameVinco Ventures, Inc. August 15, 2022 Page 2 FirstName LastName Philip Jones Vinco Ventures, Inc. August 15, 2022 Page 2 your revenue recognition policies. Cite the specific authoritative accounting guidance you relied upon in determining your accounting treatment.

•Quantify the impact of all digital assets, including NFT's, on your financial statements. Ensure that you quantify all related assets and liabilities on your balance sheet and all related revenues, cost of revenues, and other impacts on your statements of operations. Provide us with and disclose a rollforward of each material holding of digital assets included on your balance sheet.

•Explain to us in sufficient detail how your NFT platform operates. In doing so, describe the services and/or products you offer to customers, the parties involved, and key contractual terms. Considering providing illustrative examples to facilitate our understanding. In closing, 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. You may contact Beverly Singleton at (202) 551-3328 or Andrew Blume at (202) 551- 3254 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing

Show Raw Text
United States securities and exchange commission logo
August 15, 2022
Philip Jones
Chief Financial Officer
Vinco Ventures, Inc.
6 North Main Street
Fairport, New York 14450
Re:Vinco Ventures, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed April 15, 2022
File No. 001-38448
Dear Mr. Jones:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2021
Business , page 4
1.We note your disclosure on page 5 that your wholly-owned subsidiary EVNT Platform
LLC, dba Emmersive Entertainment ("EVNT"), offers a streaming music Non-Fungible
Token ("NFT") platform that generates revenue "from the development of custom, digital
artwork and digital music that is sold in the form of non-fungible tokens through a third-
party marketplace."  We also note your disclosure on page 87 that your asset acquisition
from Emmersive Entertainment, Inc. included "digital assets."  Please address the
following comments related to your digital assets:

•Tell us and disclose your accounting policies related to digital assets, including
NFT's.  Ensure your response addresses, but is not necessarily limited to, the specific
nature of the digital assets recorded on your balance sheet, how you record digital
assets upon initial recognition, how you account for them after initial recognition, and

 FirstName LastNamePhilip Jones
 Comapany NameVinco Ventures, Inc.
 August 15, 2022 Page 2
 FirstName LastName
Philip Jones
Vinco Ventures, Inc.
August 15, 2022
Page 2
your revenue recognition policies.  Cite the specific authoritative accounting
guidance you relied upon in determining your accounting treatment.

•Quantify the impact of all digital assets, including NFT's, on your financial
statements.  Ensure that you quantify all related assets and liabilities on your balance
sheet and all related revenues, cost of revenues, and other impacts on your statements
of operations.  Provide us with and disclose a rollforward of each material holding of
digital assets included on your balance sheet.

•Explain to us in sufficient detail how your NFT platform operates.  In doing so,
describe the services and/or products you offer to customers, the parties involved, and
key contractual terms.  Considering providing illustrative examples to facilitate our
understanding.
            In closing, 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.
            You may contact Beverly Singleton at (202) 551-3328 or Andrew Blume at (202) 551-
3254 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing