SEC Company Response from Nico Echo Park, Benefit Corp (CIK 0001781961) — Jan 8, 2020
Nico Echo Park, Benefit Corp (CIK 0001781961)
Date: Jan. 8, 2020 · CIK: 0001781961 · Accession: 0001104659-20-002376
AI Filing Summary & Sentiment
Referenced dates: August 9, 2019
Letter
VIA EDGAR Division of Corporation Finance Attention: Jonathan Burr, Staff Attorney Re: Nico Echo Park, Benefit Corp. Offering Statement on Form 1-A Filed December 26, 2019 CIK No. 0001781961
Dear Messers. Burr and Efron:
This letter is being submitted on behalf of Nico Echo Park, Benefit Corp. (the “Company”) in response to supplemental oral comments of the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) with respect to the Company’s Offering Statement on Form 1-A filed on December 26, 2019 (the “Offering Statement”).
As per our telephone discussions, through a scrivener’s error the changes that we had said were included in the Offering Statement in our response (the “Response Letter”) to the Staff’s letter dated August 9, 2019 addressed to Mr. Levine, Chief Executive Officer of the Company (the “Comment Letter”), were inadvertently omitted.
Attached as Appendix A to this letter are the changes noted in the Response Letter that were meant to be included in the Offering Statement. In addition to changes that address the Staff’s comments in the Comment Letter, the changed pages also reflect changes requested by the Office of Investment Management with respect to the Company’s Redemption Plan along with certain other clean-up changes to correct or clarify disclosure.
We apologize for the confusion. As we discussed with the Staff, we would appreciate the opportunity to confirm with the Staff that the attached changes fully address the comments in the Comment Letter. Assuming there are no additional comments to the Offering Statement, the
Messrs. Jonathon Burr and Howard Efron
Division of Corporation Finance
January 8, 2020
Page 2
Company expects to file a pre-qualification amendment to complete any missing information (e.g. director names, etc.) and include any remaining exhibits in advance of requesting acceleration of qualification.
If you have any questions or would like further information please do not hesitate to contact me at (212) 813-8842.
Sincerely,
Mark Schonberger
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CORRESP
1
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Goodwin Procter LLP
T: 212.813.8800
Counsellors at Law
F: 212.355.3333
New York Times Building
goodwinprocter.com
620 Eighth Avenue
New York, NY 10018
January 8, 2020
VIA EDGAR
U.S. Securities and Exchange Commission
Division
of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Attention: Jonathan Burr, Staff Attorney
Howard Efron, Staff Accountant
Re: Nico Echo Park, Benefit Corp.
Offering Statement on Form 1-A
Filed December
26, 2019
CIK No. 0001781961
Dear Messers. Burr and Efron:
This
letter is being submitted on behalf of Nico Echo Park, Benefit Corp. (the “Company”) in response to supplemental
oral comments of the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange
Commission (the “Commission”) with respect to the Company’s Offering Statement on Form 1-A filed on December
26, 2019 (the “Offering Statement”).
As per
our telephone discussions, through a scrivener’s error the changes that we had said were included in the Offering Statement
in our response (the “Response Letter”) to the Staff’s letter dated August 9, 2019 addressed to Mr. Levine,
Chief Executive Officer of the Company (the “Comment Letter”), were inadvertently omitted.
Attached
as Appendix A to this letter are the changes noted in the Response Letter that were meant to be included in the Offering
Statement. In addition to changes that address the Staff’s comments in the Comment Letter, the changed pages also reflect
changes requested by the Office of Investment Management with respect to the Company’s Redemption Plan along with certain other clean-up changes to correct or clarify disclosure.
We apologize
for the confusion. As we discussed with the Staff, we would appreciate the opportunity to confirm with the Staff that the attached
changes fully address the comments in the Comment Letter. Assuming there are no additional comments to the Offering Statement,
the
Messrs. Jonathon Burr and Howard Efron
Division of Corporation Finance
January 8, 2020
Page 2
Company expects to file a
pre-qualification amendment to complete any missing information (e.g. director names, etc.) and include any remaining exhibits
in advance of requesting acceleration of qualification.
If
you have any questions or would like further information please do not hesitate to contact me at (212) 813-8842.
Sincerely,
Mark Schonberger
cc: Via E-mail
Max Levine
John Chaffetz
Nico Echo Park, Benefit Corp.
Evyn Rabinowitz, Esq.
Goodwin Procter LLP
Appendix A