SEC Comment Letter 0000000000-23-006864 to Elite Performance Holding Corp (CIK 0001753681)
Elite Performance Holding Corp (CIK 0001753681)
Date: June 28, 2023 · CIK: 0001753681 · Accession: 0000000000-23-006864
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File numbers found in text: 333-262483
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United States securities and exchange commission logo
June 28, 2023
Joey Firestone
Chief Executive Officer
Elite Performance Holding Corporation
3301 NE 1st Ave. Suite M704
Miami, FL 33137
Re:Elite Performance Holding Corporation
Amendment No. 6 to Registration Statement on Form S-1
Filed June 6, 2023
File No. 333-262483
Dear Joey Firestone:
We have reviewed your amended registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our February 27, 2023 letter.
Amendment No. 6 to Registration Statement on Form S-1 filed June 6, 2023
Index to Financial Statements, page F-1
1.Please revise to include updated interim financial statements for the quarter ended March
31, 2023, as required by Rule 8-08 of Regulation S-X. Your MD&A section should also
be revised to discuss this interim period.
General
2.We note your response to prior comment 3. Please continue to update the disclosure
throughout the document to the extent appropriate. For example:
• Update the disclosure in the Controls and Procedures section on page 25. In this regard,
FirstName LastNameJoey Firestone
Comapany NameElite Performance Holding Corporation
June 28, 2023 Page 2
FirstName LastName
Joey Firestone
Elite Performance Holding Corporation
June 28, 2023
Page 2
we note the disclosure in this section, including the reference on page 25 to "During the
most recent fiscal quarter," is identical to the disclosure on page 25 of your amendment
filed on February 21, 2023.
• Update the disclosure in the Related Party Transactions section on page 31, such as the
disclosure about balances as of December 31, 2022, and the disclosure on page 19 about
the number of holders of record as of June 30, 2022.
You may contact Claire Erlanger, Staff Accountant, at 202-551-3301 or Andrew Blume,
Senior Accountant, at 202-551-3254 if you have questions regarding comments on the financial
statements and related matters. Please contact Thomas Jones, Staff Attorney, at 202-551-3602 or
Geoff Kruczek, Senior Attorney, at 202-551-3641 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Matheau J. W. Stout