SEC Comment Letter 0000000000-23-003934 to Lucent, Inc. (CIK 0001778343)
Lucent, Inc. (CIK 0001778343)
Date: April 19, 2023 · CIK: 0001778343 · Accession: 0000000000-23-003934
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File numbers found in text: 000-56509
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United States securities and exchange commission logo
April 19, 2023
Steven Arenal
Chief Executive Officer
Lucent, Inc.
1633 East Fourth Street
Suite 148
Santa Ana, CA 92701
Re:Lucent, Inc.
Amendment No. 4 to Form 10
Filed April 10, 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. 4 to Form 10-12G
Item 1. Description of Business, page 1
1.We partially reissue comment 1. Please revise the discussion of the prior failure to file
periodic reports to clearly disclose that the potential actions relate to the risk that the
company may again fail to file periodic reports going forward. Please also address the
risk to investors if you continue to be delinquent or become delinquent again in the
future. Lastly, as previously requested, please revise the risk factor subheading on page 6
to make it clear the risk relates to the company's failure to file required periodic reports.
Item 5. Directors and Executive Officers, page 12
2.We note your response to comment 2 of our letter. Please remove the mitigating language
from the risk factor on page 6. Additionally, we note that you have not included all of the
FirstName LastNameSteven Arenal
Comapany NameLucent, Inc.
April 19, 2023 Page 2
FirstName LastName
Steven Arenal
Lucent, Inc.
April 19, 2023
Page 2
potential conflicts of interest. For example only, discuss the conflicts of interest relating
to identifying a target business, and allocation of time and resources of management.
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.