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SEC Comment Letter for BestGofer Inc. (BGFR) (CIK 0001722556) (BGFR) — Apr 25, 2018

BestGofer Inc. (BGFR) (CIK 0001722556)
Date: April 25, 2018 · CIK: 0001722556 · Accession: 0000000000-18-012724

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 333-224041

Date
April 25, 2018
Author
President
Form
UPLOAD
Company
BestGofer Inc. (BGFR) (CIK 0001722556)

Letter

April 25, 2018 Gal Abotbol President Best Gofer, Inc 401 Ryland Street, Suite 200-A Reno, NV 89502 Re:Best Gofer, Inc Registration Statement on Form S-1 Filed March 30, 2018 File No. 333-224041 Dear Mr. Abotbol: We have reviewed your registration statement 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 this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Form S-1 Filed March 30, 2018 Summary of Prospectus, page 4 1.Please disclose in your Summary of Prospectus your current business plans and your current ability to provide those services. For example, disclose where you intend to operate your delivery business. Risk Factors, page 5 2.We note that you are principally located in Israel. Please include a risk factor discussing any applicable government regulations that may affect a shareholder’s right to enforce judgments against the company and its officers and director. To provide context,

FirstName LastNameGal Abotbol Comapany NameBest Gofer, Inc June 16, 2017 Page 2 FirstName LastNameGal Abotbol Best Gofer, Inc April 25, 2018 Page 2 disclose the location and nationality of your officers and director. Revise other disclosures throughout your registration as you deem appropriate to include this information. Description of Business, page 16 3.Expand your disclosure to further discuss items that will be prohibited for purchase through your phone application. 4.Please discuss all material regulations that will be applicable to your planned operations (e.g., those regulating credit card use, privacy, employer liability, etc.). 5.Please discuss in more detail the type of products you plan to have available through your application. Please also discuss how customers will identify specific items for purchase (e.g., through a catalog, through a store inventory list, etc.). BestGofer, Drivers, page 17 6.Please clarify if the individuals who will be delivering items on behalf of the company will be independent contractors or employees. Also discuss how you plan to recruit such individuals. Signatures, page 29 7.Please revise to reflect whether Messrs. Abotbol and/or Yehuda are signing the registration statement in the capacities required by Form S-1. See Instructions 1 and 2 to Signatures of Form S-1. In addition, include notations to reflect that each individual has signed the registration statement. See Rule 402(e) of Regulatin C. 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. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.

FirstName LastNameGal Abotbol Comapany NameBest Gofer, Inc June 16, 2017 Page 3 FirstName LastName Gal Abotbol Best Gofer, Inc April 25, 2018 Page 3 You may contact Kathryn Jacobson, Staff Accountant, at 202-551-3365 or Carlos Pacho, Senior Assistant Chief Accountant, at 202-551-3835 if you have questions regarding comments on the financial statements and related matters. Please contact Courtney Lindsay, Staff Attorney, at 202-551-7237 or Larry Spirgel, Assistant Director, at 202-551-3810 with any other questions. Division of Corporation Finance Office of Telecommunications

Show Raw Text
April 25, 2018
Gal Abotbol
President
Best Gofer, Inc
401 Ryland Street, Suite 200-A
Reno, NV 89502
Re:Best Gofer, Inc
Registration Statement on Form S-1
Filed March 30, 2018
File No. 333-224041
Dear Mr. Abotbol:
            We have reviewed your registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form S-1 Filed March 30, 2018
Summary of Prospectus, page 4
1.Please disclose in your Summary of Prospectus your current business plans and your
current ability to provide those services.  For example,  disclose where you intend to
operate your delivery business.
Risk Factors, page 5
2.We note that you are principally located in Israel.  Please include a risk factor
discussing any applicable government regulations that may affect a shareholder’s right to
enforce judgments against the company and its officers and director. To provide context,

 FirstName LastNameGal Abotbol
 Comapany NameBest Gofer, Inc
 June 16, 2017 Page 2
 FirstName LastNameGal Abotbol
Best Gofer, Inc
April 25, 2018
Page 2
disclose the location and nationality of your officers and director.  Revise other
disclosures throughout your registration as you deem appropriate to include this
information.
Description of Business, page 16
3.Expand your disclosure to further discuss items that will be prohibited for purchase
through your phone application.
4.Please discuss all material regulations that will be applicable to your planned operations
(e.g., those regulating credit card use, privacy, employer liability, etc.).
5.Please discuss in more detail the type of products you plan to have available through your
application.  Please also discuss how customers will identify specific items for purchase
(e.g., through a catalog, through a store inventory list, etc.).
BestGofer, Drivers, page 17
6.Please clarify if the individuals who will be delivering items on behalf of the company
will be independent contractors or employees.  Also discuss how you plan to recruit such
individuals.
Signatures, page 29
7.Please revise to reflect whether Messrs. Abotbol and/or Yehuda are signing the
registration statement in the capacities required by Form S-1.  See Instructions 1 and 2 to
Signatures of Form S-1.  In addition, include notations to reflect that each individual has
signed the registration statement.  See Rule 402(e) of Regulatin C.
             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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

 FirstName LastNameGal Abotbol
 Comapany NameBest Gofer, Inc
 June 16, 2017 Page 3
 FirstName LastName
Gal Abotbol
Best Gofer, Inc
April 25, 2018
Page 3
            You may contact Kathryn Jacobson, Staff Accountant, at 202-551-3365 or Carlos Pacho,
Senior Assistant Chief Accountant, at 202-551-3835 if you have questions regarding comments
on the financial statements and related matters.  Please contact Courtney Lindsay, Staff Attorney,
at 202-551-7237 or Larry Spirgel, Assistant Director, at 202-551-3810 with any other questions.
Division of Corporation Finance
Office of Telecommunications