Correspondence 0001493152-24-026036 from MODE MOBILE, INC. (CIK 0001748441)
MODE MOBILE, INC. (CIK 0001748441)
Date: July 2, 2024 · CIK: 0001748441 · Accession: 0001493152-24-026036
AI Filing Summary & Sentiment
File numbers found in text: 024-12419
Referenced dates: June 27, 2024
Letter
Division of Corporation Finance Office of Technology Securities and Exchange Commission Amendment No. 1 to Offering Statement on Form 1-A Filed June 11, 2024 File No. 024-12419
Re: Mode Mobile, Inc.
Dear Mr. Spirgel:
We acknowledge receipt of the comments in the letter dated June 27, 2024 from the staff of the Division of Corporate Finance - Office of Technology (the “Staff”) the regarding the Offering Statement of Mode Mobile. Inc. (the “Company”), which we have set out below, together with our responses.
Amendment No., 1 to Offering Statement on Form 1-A
Our Business, page 17
1. We note your disclosure that “The buildout and launch of the $CRNC Network will be carried out by a foundation established by CGL,” and that “the Company will completely divest its interest and involvement in the $CRNC Network.” To the extent known, please revise to clarify whether the foundation will be a related party, the nature of the relationship, and whether management of Mode Mobile or CGL will be involved in the operations of the foundation.
The Company has revised its disclosure regarding the $CRNC Network to clarify that CGL will have no control of oversight of the foundation once it is established. As such, the foundation will not be a related party and no members of management of Mode Mobile or CGL will be involved in the operations of the foundation.
Exhibits
2. Your legal opinion filed as Exhibit 5 refers to up to 150 million Class AAA common stock shares being offered by your selling stockholders, but your Offering Circular discloses that only 30 million Class AAA common stock shares are being offered by your selling stockholders. Please clarify or provide a revised legal opinion.
A revised legal opinion is being provided that corrects the description of the shares being offered by selling stockholders in this Offering.
Thank you again for the opportunity to respond to your questions to the Offering Statement of Mode Mobile, Inc. If you have additional questions or comments, please contact me at andrew@crowdchecklaw.com.
Sincerely,
/s/
Andrew Stephenson
Show Raw Text
CORRESP
1
filename1.htm
July
2, 2024
Attn:
Mr. Larry Spirgel
Office
Chief
Division
of Corporation Finance
Office
of Technology
Securities
and Exchange Commission
Washington
DC 20549
Re:
Mode Mobile, Inc.
Amendment No. 1 to Offering Statement on Form 1-A
Filed June 11, 2024
File No. 024-12419
Dear
Mr. Spirgel:
We
acknowledge receipt of the comments in the letter dated June 27, 2024 from the staff of the Division of Corporate Finance - Office of
Technology (the “Staff”) the regarding the Offering Statement of Mode Mobile. Inc. (the “Company”), which we
have set out below, together with our responses.
Amendment
No., 1 to Offering Statement on Form 1-A
Our
Business, page 17
1. We
note your disclosure that “The buildout and launch of the $CRNC Network will be carried
out by a foundation established by CGL,” and that “the Company will completely
divest its interest and involvement in the $CRNC Network.” To the extent known, please
revise to clarify whether the foundation will be a related party, the nature of the relationship,
and whether management of Mode Mobile or CGL will be involved in the operations of the foundation.
The
Company has revised its disclosure regarding the $CRNC Network to clarify that CGL will have no control of oversight of the foundation
once it is established. As such, the foundation will not be a related party and no members of management of Mode Mobile or CGL will be
involved in the operations of the foundation.
Exhibits
2. Your
legal opinion filed as Exhibit 5 refers to up to 150 million Class AAA common stock shares
being offered by your selling stockholders, but your Offering Circular discloses that only
30 million Class AAA common stock shares are being offered by your selling stockholders.
Please clarify or provide a revised legal opinion.
A
revised legal opinion is being provided that corrects the description of the shares being offered by selling stockholders in this Offering.
Thank
you again for the opportunity to respond to your questions to the Offering Statement of Mode Mobile, Inc. If you have additional questions
or comments, please contact me at andrew@crowdchecklaw.com.
Sincerely,
/s/
Andrew Stephenson
Andrew Stephenson
Partner
CrowdCheck Law LLP
cc:
Dan Novaes
CEO
of Mode Mobile, Inc.