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SEC Comment Letter 0000000000-23-002775 to APPlife Digital Solutions Inc (ALDS)

APPlife Digital Solutions Inc
Date: March 20, 2023 · CIK: 0001755101 · Accession: 0000000000-23-002775

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File numbers found in text: 333-269389

Date
March 20, 2023
Author
Office of Technology
Form
UPLOAD
Company
APPlife Digital Solutions Inc

Letter

United States securities and exchange commission logo March 20, 2023 Matthew Reid Chief Executive Officer APPlife Digital Solutions Inc. 50 California St, #1500 San Francisco, CA 94111 Re:APPlife Digital Solutions Inc. Amendment No. 2 to Registration Statement on Form S-1 Filed March 6, 2023 File No. 333-269389 Dear Matthew Reid: 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 March 2, 2022 letter. Amendment No. 2 to Registration Statement on Form S-1 Description of Business Product, page 20 1.We note your response to prior comment 2 and reissue it, in part. Please highlight the risk that you may be liable for any cybersecurity breach resulting in the loss of customer assets. 2.We note your response to prior comment 3. Please include the information provided in your response letter in your filing. For example, disclose that you expect users to store their important documents and certificates in files and that your interface will be tailored to cater to file storage.

FirstName LastNameMatthew Reid Comapany NameAPPlife Digital Solutions Inc. March 20, 2023 Page 2 FirstName LastName Matthew Reid APPlife Digital Solutions Inc. March 20, 2023 Page 2 General 3.We note your response to prior comment 4. Please include the information provided in your response letter in your filing. For example, disclose that, while Matt Reid is your only employee, you manage multiple independent contractor teams to operate your U.S. based business and that 100% of your revenue comes from servicing U.S. customers. Please contact Kyle Wiley, Staff Attorney, at (202) 344-5791 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Chase Chandler

Show Raw Text
United States securities and exchange commission logo
March 20, 2023
Matthew Reid
Chief Executive Officer
APPlife Digital Solutions Inc.
50 California St, #1500
San Francisco, CA 94111
Re:APPlife Digital Solutions Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed March 6, 2023
File No. 333-269389
Dear Matthew Reid:
            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 March 2, 2022 letter.
Amendment No. 2 to Registration Statement on Form S-1
Description of Business
Product, page 20
1.We note your response to prior comment 2 and reissue it, in part. Please highlight the risk
that you may be liable for any cybersecurity breach resulting in the loss of customer
assets.
2.We note your response to prior comment 3. Please include the information provided in
your response letter in your filing. For example, disclose that you expect users to store
their important documents and certificates in files and that your interface will be tailored
to cater to file storage.

 FirstName LastNameMatthew Reid
 Comapany NameAPPlife Digital Solutions Inc.
 March 20, 2023 Page 2
 FirstName LastName
Matthew Reid
APPlife Digital Solutions Inc.
March 20, 2023
Page 2
General
3.We note your response to prior comment 4. Please include the information provided in
your response letter in your filing. For example, disclose that, while Matt Reid is your
only employee, you manage multiple independent contractor teams to operate your U.S.
based business and that 100% of your revenue comes from servicing U.S. customers.
            Please contact Kyle Wiley, Staff Attorney, at (202) 344-5791 or Jan Woo, Legal Branch
Chief, at (202) 551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Chase Chandler