Correspondence 0001493152-24-028288 from MODE MOBILE, INC. (CIK 0001748441)
MODE MOBILE, INC. (CIK 0001748441)
Date: July 18, 2024 · CIK: 0001748441 · Accession: 0001493152-24-028288
AI Filing Summary & Sentiment
File numbers found in text: 024-12419
Letter
Division of Corporation Finance Office of Technology Securities and Exchange Commission Mode Mobile, Inc. Amendment No. 2 to Offering Statement on Form 1-A Filed July 2, 2024 File No. 024-12419
Re:
Dear Mr. Spirgel:
We acknowledge receipt of the verbal comments delivered on July 17, 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”), to which we provide the below response.
On July 17, 2024 a verbal comment was conveyed requesting additional detail to support the Company’s statements on page 17 of the offering circular that neither the Company nor its management will have control of the $CRNC network or a role in the ongoing governance of that network, which will become the responsibility of $CRNC stakeholders as a collective group. To provide additional support for that claim, the Company is providing the following details regarding ownership of $CRNC tokens by the Company and its management:
Name of beneficial owner Amount and nature of beneficial ownership of $CRNC Tokens Percentage Ownership
Mode Mobile, Inc. - 0 %
Dan Novaes 48,000,000 4.95 %
Kiran Panesar 24,000,000 2.48 %
Justin Hines 2,040,000 0.21 %
Kathy DeKam 1,550,000 0.16 %
Prakash Ramachandran 1,550,000 0.16
Company and Affiliates as a Group 75,590,000 7.8 %
As such, the ownership of $CRNC tokens by the Company and its management is not sufficient to exercise control of the $CRNC network individually or as a group.
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
18, 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. 2 to Offering Statement on Form 1-A
Filed
July 2, 2024
File
No. 024-12419
Dear
Mr. Spirgel:
We
acknowledge receipt of the verbal comments delivered on July 17, 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”), to which
we provide the below response.
On
July 17, 2024 a verbal comment was conveyed requesting additional detail to support the Company’s statements on page 17 of the
offering circular that neither the Company nor its management will have control of the $CRNC network or a role in the ongoing governance
of that network, which will become the responsibility of $CRNC stakeholders as a collective group. To provide additional support for
that claim, the Company is providing the following details regarding ownership of $CRNC tokens by the Company and its management:
Name of beneficial owner
Amount and nature of beneficial ownership of $CRNC Tokens
Percentage Ownership
Mode Mobile, Inc.
-
0 %
Dan Novaes
48,000,000
4.95 %
Kiran Panesar
24,000,000
2.48 %
Justin Hines
2,040,000
0.21 %
Kathy DeKam
1,550,000
0.16 %
Prakash Ramachandran
1,550,000
0.16
Company and Affiliates as a Group
75,590,000
7.8 %
As
such, the ownership of $CRNC tokens by the Company and its management is not sufficient to exercise control of the $CRNC network individually
or as a group.
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.