SEC Comment Letter 0000000000-23-008066 to Elvictor Group, Inc. (ELVG) (CIK 0001741489) (ELVG)
Elvictor Group, Inc. (ELVG) (CIK 0001741489)
Date: July 27, 2023 · CIK: 0001741489 · Accession: 0000000000-23-008066
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File numbers found in text: 000-56508
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United States securities and exchange commission logo
July 27, 2023
Konstantinos Galanakis
Chief Executive Officer and Chief Financial Officer
Elvictor Group, Inc.
Vassileos Constantinou 79
Vari, Attiki, Greece 16672
Re:Elvictor Group, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
File No. 000-56508
Dear Konstantinos Galanakis:
We have limited our review of your filing to the financial statements and related
disclosures 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 comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2022
Item 9A. Controls and Procedures
Management’s Report on Internal Control over Financial Reporting, page 14
1.Please revise your report of management on the internal control over financial reporting
to include a statement of management's responsibility for establishing and maintaining
adequate internal control over financial reporting and a statement identifying the
framework used by management to evaluate the effectiveness of the internal control over
financial reporting (e.g. 2013 edition). Refer to Item 308(a)(1) and (2) of Regulation S-K
FirstName LastNameKonstantinos Galanakis
Comapany NameElvictor Group, Inc.
July 27, 2023 Page 2
FirstName LastName
Konstantinos Galanakis
Elvictor Group, Inc.
July 27, 2023
Page 2
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 Stephen Kim at 202-551-3291 or Theresa Brillant at 202-551-3307 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services