SEC Comment Letter 0000000000-23-003143 to Lucent, Inc. (CIK 0001778343)
Lucent, Inc. (CIK 0001778343)
Date: March 29, 2023 · CIK: 0001778343 · Accession: 0000000000-23-003143
AI Filing Summary & Sentiment
File numbers found in text: 000-56509
Letter
United States securities and exchange commission logo March 29, 2023 Steven Arenal Chief Executive Officer Lucent, Inc. 1633 East Fourth Street Suite 148 Santa Ana, CA 92701 Re:Lucent, Inc. Amendment No. 3 to Form 10 Filed March 21, 2023 File No. 000-56509 Dear Steven Arenal: We have reviewed your 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. Amendment No. 3 to Form 10-12G Item 1. Description of Business (a) Business Development, page 1 1.We note your response to comment 1 of our letter and reissue in part. We note that you have not included all the risks associated with failure to timely file Exchange Act reports. For example only, we note that you did not address the risk that the SEC could suspend trading or revoke your registration statement. Please also address the risk to investors if you continue to be delinquent or become delinquent again in the future. Please ensure that you disclose all risks. Lastly, please revise the risk factor subheading to make it clear the risk relates to the company's failure to file required periodic reports.
FirstName LastNameSteven Arenal Comapany NameLucent, Inc. March 29, 2023 Page 2 FirstName LastName Steven Arenal Lucent, Inc. March 29, 2023 Page 2 Item 5. Directors and Executive Officers, page 12 2.We note your response to comment 3. We note your disclosure that Mr. Arenal has invested in companies through a family office and that he helped start a bank. Please clarify Mr. Arenal's roles with these entities. To the extent he held a position with the companies or with the bank in the past five years, please disclose this. Additionally, please identify any conflicts associated with having at least two companies that would currently be seeking merger candidates. 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 Peter McPhun at 202-551-3581 or Jennifer Monick at 202-551-3295 if you have questions regarding comments on the financial statements and related matters. Please contact Stacie Gorman at 202-551-3585 or Pam Howell at 202-551-3357 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Byron Thomas, Esq.
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United States securities and exchange commission logo
March 29, 2023
Steven Arenal
Chief Executive Officer
Lucent, Inc.
1633 East Fourth Street
Suite 148
Santa Ana, CA 92701
Re:Lucent, Inc.
Amendment No. 3 to Form 10
Filed March 21, 2023
File No. 000-56509
Dear Steven Arenal:
We have reviewed your 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.
Amendment No. 3 to Form 10-12G
Item 1. Description of Business
(a) Business Development, page 1
1.We note your response to comment 1 of our letter and reissue in part. We note that you
have not included all the risks associated with failure to timely file Exchange Act reports.
For example only, we note that you did not address the risk that the SEC could suspend
trading or revoke your registration statement. Please also address the risk to investors if
you continue to be delinquent or become delinquent again in the future. Please ensure that
you disclose all risks. Lastly, please revise the risk factor subheading to make it clear the
risk relates to the company's failure to file required periodic reports.
FirstName LastNameSteven Arenal
Comapany NameLucent, Inc.
March 29, 2023 Page 2
FirstName LastName
Steven Arenal
Lucent, Inc.
March 29, 2023
Page 2
Item 5. Directors and Executive Officers, page 12
2.We note your response to comment 3. We note your disclosure that Mr. Arenal has
invested in companies through a family office and that he helped start a bank. Please
clarify Mr. Arenal's roles with these entities. To the extent he held a position with the
companies or with the bank in the past five years, please disclose this. Additionally,
please identify any conflicts associated with having at least two companies that would
currently be seeking merger candidates.
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 Peter McPhun at 202-551-3581 or Jennifer Monick at 202-551-3295 if
you have questions regarding comments on the financial statements and related matters. Please
contact Stacie Gorman at 202-551-3585 or Pam Howell at 202-551-3357 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Byron Thomas, Esq.