SEC Comment Letter 0000000000-23-008535 to Elvictor Group, Inc. (ELVG) (CIK 0001741489) (ELVG)
Elvictor Group, Inc. (ELVG) (CIK 0001741489)
Date: Aug. 7, 2023 · CIK: 0001741489 · Accession: 0000000000-23-008535
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United States securities and exchange commission logo
August 7, 2023
Konstantinos Galanakis
Chief Executive Officer and Chief Financial Officer
Elvictor Group, Inc.
Vassileos Constantinou 79
Vari, Attiki, Greece 16672
Re:Elvictor Group, Inc.
Amendment No. 1 to 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.
Amendment No. 1 to Form 10-K for Fiscal Year Ended December 31, 2022
Item 9A. Controls and Procedures, page 1
1.We note your response and related amended Form 10-K to our comment 1 and we reissue
our comment in part. Please revise your report of management on the internal control
over financial reporting to include a statement identifying the framework used by
management to evaluate the effectiveness of the internal control over financial reporting
[e.g. framework set forth by the Committee of Sponsoring Organizations of the Treadway
Commission in Internal Control—Integrated Framework (the 2013 framework)]. Refer to
Item 308(a)(2) of Regulation S-K.
FirstName LastNameKonstantinos Galanakis
Comapany NameElvictor Group, Inc.
August 7, 2023 Page 2
FirstName LastName
Konstantinos Galanakis
Elvictor Group, Inc.
August 7, 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