SEC Comment Letter for Red Violet, Inc. (RDVT) (CIK 0001720116) (RDVT) — Feb 13, 2018
Red Violet, Inc. (RDVT) (CIK 0001720116)
Date: Feb. 13, 2018 · CIK: 0001720116 · Accession: 0000000000-18-004984
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4561 February 13, 2018 Derek Dubner Chief Executive Officer Red Violet, Inc. 2650 North Military Trail, Suite 300 Boca Raton, FL 33431
Re: Red Violet, Inc. Amendment No. 2 to Draft Registration Statement on Form 10 Submitted February 2 , 2018 CIK No. 0001720116
Dear Mr. Dubner :
We have reviewed your amended draft registration statement and have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comment applies to your facts and circumst ances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to this comment and your amended draft registration statement or filed registration statement, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our January 25, 2018 letter .
Business
Concentration of Supplie rs, page 44
1. We note your response to prior comment 1. Please provide us with a more detailed analysis regarding why you believe the identity of your largest data supplier is not material to investors. As part of your response, disclose the costs related to this supplier as a percentage of your total data acquisition cost s. Further, to the extent material, revise to expand your risk factor to disclose your reliance on the supplier and the company’s ability to replace this supplier if necessary
Derek Dubner Red Violet, Inc. February 13 , 2018 Page 2
You may c ontact Rebekah Lindsey, Staff Accountant, at (202) 551 -3303 or Kathleen Collins, Accounting Branch Chief, at (202) 551 -3499 if you have questions regarding the financial statements and related matters. Please contact Matthew Derby, Attorney -Advisor, at (202) 551 -3334 or , in his absence, you may contact Jan Woo at (202) 551 -3453 . If you require further assistance, please contact Barbara C. Jacobs, Assistant Director, at (202) 551 -3730.
Sincerely,
/s/ Kathleen Collins
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Mail Stop 4561 February 13, 2018 Derek Dubner Chief Executive Officer Red Violet, Inc. 2650 North Military Trail, Suite 300 Boca Raton, FL 33431 Re: Red Violet, Inc. Amendment No. 2 to Draft Registration Statement on Form 10 Submitted February 2 , 2018 CIK No. 0001720116 Dear Mr. Dubner : We have reviewed your amended draft registration statement and have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comment applies to your facts and circumst ances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to this comment and your amended draft registration statement or filed registration statement, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our January 25, 2018 letter . Business Concentration of Supplie rs, page 44 1. We note your response to prior comment 1. Please provide us with a more detailed analysis regarding why you believe the identity of your largest data supplier is not material to investors. As part of your response, disclose the costs related to this supplier as a percentage of your total data acquisition cost s. Further, to the extent material, revise to expand your risk factor to disclose your reliance on the supplier and the company’s ability to replace this supplier if necessary Derek Dubner Red Violet, Inc. February 13 , 2018 Page 2 You may c ontact Rebekah Lindsey, Staff Accountant, at (202) 551 -3303 or Kathleen Collins, Accounting Branch Chief, at (202) 551 -3499 if you have questions regarding the financial statements and related matters. Please contact Matthew Derby, Attorney -Advisor, at (202) 551 -3334 or , in his absence, you may contact Jan Woo at (202) 551 -3453 . If you require further assistance, please contact Barbara C. Jacobs, Assistant Director, at (202) 551 -3730. Sincerely, /s/ Kathleen Collins Kathleen Collins Accounting Branch Chief Office of Information Technologies and Services cc: Josh Weingard, Esq. Corporate Counsel and Secretary Cogint, Inc.