SEC Company Response from Elvictor Group, Inc. (ELVG) (CIK 0001741489) (ELVG) — Apr 14, 2020
Elvictor Group, Inc. (ELVG) (CIK 0001741489)
Date: April 14, 2020 · CIK: 0001741489 · Accession: 0001520138-20-000165
AI Filing Summary & Sentiment
File numbers found in text: 333-225239
Referenced dates: April 13, 2020
Letter
RE: Elvictor Group, Inc.
ELVICTOR GROUP, INC.
April 13, 2020
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Post-effective Amendment No. 5 to Registration Statement on Form S-1
Filed April 7, 2020
File No. 333-225239
Ladies and Gentlemen:
On behalf of our Company, Elvictor Group, Inc. (the “Company”), we are filing with the Securities and Exchange Commission (the “Commission”), Amendment No. 6 to the Offering Statement on Post Effective Form S-1 (“Amendment No. 6”) registration for resale certain shares described therein (the “Offering”).
This letter also sets forth the Company’s responses to comments from the staff (the “Staff”) of the Division of Corporation Finance of the Commission contained in the Staff’s letter dated April 13, 2020 regarding your review of the Amended Offering Statement on Form S-1, which was filed with the Commission on April 7, 2020.
For your convenience, the Staff’s comments have been repeated below in their entirety, with the Company’s response to a particular comment set out immediately underneath it. The headings and numbered paragraphs in this letter correspond to the headings and numbered paragraphs in the comment letter from the Staff. When indicated, the responses described below are included in Amendment No. 6. Capitalized terms used but not defined in this letter are intended to have the meanings ascribed to such terms in Amendment No 6.
Post-effective amendment No. 5 Registration Statement on Form S-1
Prospectus Cover Page, page i
The Offering, page 3
1. We reissue comment 2. Please revise your prospectus to consistently describe this offering as a resale transaction and state you will receive no proceeds from this offering.
We have removed all references to funds being raised from this offering.
Where You Can Find More Information, page 37
2. Notwithstanding that we note you have filed your annual report on Form 10-K for fiscal year 2019 on April 3, 2020, we reissue comment 3. Please revise this section to remove references to documents incorporated by reference.
We have removed the language related to incorporation by reference.
Signatures, page II-5
3. We reissue comment 4. Please provide the signatures for your principal financial officeror CFO, and your principal accounting officer or controller, as required by the Instructions to the Signatures on Form S-1. If a person is acting in more than one capacity, please indicate each capacity in which the person signs.
We have added the signature of the principal accounting officer and CFO.
If you have any questions or comments regarding these responses or require any additional information, please do not hesitate to contact me or our counsel, Eilers Law Group, P.A. at (786) 273-9152.
Very truly
yours,
/s/ Panagiotis Tolis
Show Raw Text
CORRESP 1 filename1.htm ELVICTOR GROUP, INC. April 13, 2020 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F. Street, N.E. Washington, D.C. 20549 RE: Elvictor Group, Inc. Post-effective Amendment No. 5 to Registration Statement on Form S-1 Filed April 7, 2020 File No. 333-225239 Ladies and Gentlemen: On behalf of our Company, Elvictor Group, Inc. (the “Company”), we are filing with the Securities and Exchange Commission (the “Commission”), Amendment No. 6 to the Offering Statement on Post Effective Form S-1 (“Amendment No. 6”) registration for resale certain shares described therein (the “Offering”). This letter also sets forth the Company’s responses to comments from the staff (the “Staff”) of the Division of Corporation Finance of the Commission contained in the Staff’s letter dated April 13, 2020 regarding your review of the Amended Offering Statement on Form S-1, which was filed with the Commission on April 7, 2020. For your convenience, the Staff’s comments have been repeated below in their entirety, with the Company’s response to a particular comment set out immediately underneath it. The headings and numbered paragraphs in this letter correspond to the headings and numbered paragraphs in the comment letter from the Staff. When indicated, the responses described below are included in Amendment No. 6. Capitalized terms used but not defined in this letter are intended to have the meanings ascribed to such terms in Amendment No 6. Post-effective amendment No. 5 Registration Statement on Form S-1 Prospectus Cover Page, page i The Offering, page 3 1. We reissue comment 2. Please revise your prospectus to consistently describe this offering as a resale transaction and state you will receive no proceeds from this offering. We have removed all references to funds being raised from this offering. Where You Can Find More Information, page 37 2. Notwithstanding that we note you have filed your annual report on Form 10-K for fiscal year 2019 on April 3, 2020, we reissue comment 3. Please revise this section to remove references to documents incorporated by reference. We have removed the language related to incorporation by reference. Signatures, page II-5 3. We reissue comment 4. Please provide the signatures for your principal financial officeror CFO, and your principal accounting officer or controller, as required by the Instructions to the Signatures on Form S-1. If a person is acting in more than one capacity, please indicate each capacity in which the person signs. We have added the signature of the principal accounting officer and CFO. If you have any questions or comments regarding these responses or require any additional information, please do not hesitate to contact me or our counsel, Eilers Law Group, P.A. at (786) 273-9152. Very truly yours, /s/ Panagiotis Tolis Panagiotis Tolis, Chief Investor Relations Officer Elvictor Group, Inc. cc: William R. Eilers, Esq.