SEC Comment Letter 0000000000-23-005393 to Tenaya Group, Inc. (CIK 0001739208)
Tenaya Group, Inc. (CIK 0001739208)
Date: May 19, 2023 · CIK: 0001739208 · Accession: 0000000000-23-005393
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File numbers found in text: 000-56524
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United States securities and exchange commission logo
May 19, 2023
Steven Arenal
President
Tenaya Group, Inc.
626 Wilshire Blvd., Suite 410
Los Angeles, CA 90017
Re:Tenaya Group, Inc.
Amendment No. 1 to Form 10-12G
Filed April 27, 2023
File No. 000-56524
Dear Steven Arenal:
We have reviewed your filing 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 and any amendment you may file in response to these
comments, we may have additional comments.
Form 10-12G/A filed April 27, 2023
Item 5. Directors and Executive Officers, page 13
1.We note your response to prior comment number 7. Please revise to indicate the principal
business conducted by Hutton Private Finance. Also revise to address Mr. Arenal's work
with Lucent Inc. which is another blank check company where he is an officer and
director of the company and also the company's majority shareholder.
Item 7. Certain Relationships and Related Transactions, and Director Independence, page 15
2.We note your response to comment number 9. Please revise to include the disclosure
required by Item 404(a)(5) of Regulation S-K. Also revise your disclosure to identify the
officer who loaned the company $8,215.
3.Please revise to address the potential conflicts of interest with Steve Arenal’s involvement
FirstName LastNameSteven Arenal
Comapany NameTenaya Group, Inc.
May 19, 2023 Page 2
FirstName LastName
Steven Arenal
Tenaya Group, Inc.
May 19, 2023
Page 2
with Lucent, Inc.
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 Jeffrey Lewis at 202-551-6216 or Robert Telewicz at 202-551-3438 if
you have questions regarding comments on the financial statements and related matters. Please
contact Pearlyne Paulemon at 202-551-8714 or David Link at 202-551-3356 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Byron Thomas