SEC Comment Letter for Kaival Brands Innovations Group, Inc. (KAVL) (CIK 0001762239) (KAVL) — Apr 8, 2019
Kaival Brands Innovations Group, Inc. (KAVL) (CIK 0001762239)
Date: April 8, 2019 · CIK: 0001762239 · Accession: 0000000000-19-006726
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-56016
Letter
April 5, 2019 Nirajkumar Patel Chief Executive Officer Quick Start Holdings, Inc. 401 N. Wickham Road, Suite 130 Melbourne, FL 32935 Re:Quick Start Holdings, Inc. Amendment No. 2 to Registration Statement on Form 10-12G Filed March 25, 2019 File No. 000-56016 Dear Mr. Patel: We have reviewed your amended filing 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 these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response and any amendment you may file 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 1, 2019 letter. Amendment No. 2 to Form 10 Prior and Current Shell Company Experience of Former Management and Former Majority Stockholder, page 10 1.We reissue prior comment 2. Your response explains why you believe that NL One was not a "blank check company;" however, you should disclose in the filing that NL One was a "shell company" as defined in Rule 12b-2 of the Exchange Act. Please revise. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact James Giugliano at 202-551-3319 or Rufus Decker at 202-551-3769 if you have questions regarding comments on the financial statements and related matters. Please
FirstName LastNameNirajkumar Patel Comapany NameQuick Start Holdings, Inc. April 5, 2019 Page 2 FirstName LastName Nirajkumar Patel Quick Start Holdings, Inc. April 5, 2019 Page 2 contact Pam Howell at 202-551-3357 or Brigitte Lippmann at 202-551-3713 with any other questions. Sincerely, Division of Corporation Finance Office of Beverages, Apparel and Mining
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April 5, 2019
Nirajkumar Patel
Chief Executive Officer
Quick Start Holdings, Inc.
401 N. Wickham Road, Suite 130
Melbourne, FL 32935
Re:Quick Start Holdings, Inc.
Amendment No. 2 to Registration Statement on Form 10-12G
Filed March 25, 2019
File No. 000-56016
Dear Mr. Patel:
We have reviewed your amended filing 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response and any amendment you may file 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 1, 2019 letter.
Amendment No. 2 to Form 10
Prior and Current Shell Company Experience of Former Management and Former Majority
Stockholder, page 10
1.We reissue prior comment 2. Your response explains why you believe that NL One was
not a "blank check company;" however, you should disclose in the filing that NL One was
a "shell company" as defined in Rule 12b-2 of the Exchange Act. Please revise.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact James Giugliano at 202-551-3319 or Rufus Decker at 202-551-3769 if
you have questions regarding comments on the financial statements and related matters. Please
FirstName LastNameNirajkumar Patel
Comapany NameQuick Start Holdings, Inc.
April 5, 2019 Page 2
FirstName LastName
Nirajkumar Patel
Quick Start Holdings, Inc.
April 5, 2019
Page 2
contact Pam Howell at 202-551-3357 or Brigitte Lippmann at 202-551-3713 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Beverages, Apparel and
Mining