SEC Comment Letter for Excellerant, Inc. (CIK 0001786119) — Jan 10, 2020
Excellerant, Inc. (CIK 0001786119)
Date: Jan. 10, 2020 · CIK: 0001786119 · Accession: 0000000000-20-000260
AI Filing Summary & Sentiment
File numbers found in text: 333-234796
Letter
January 10, 2020 Lasha Morbedadze President, Treasurer, Secretary and Director Excellerant, Inc. 302 Yayun Ave, Panyu, Guangzhou, Guangdong 510000, China Re:Excellerant, Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed December 30, 2019 File No. 333-234796 Dear Mr. Morbedadze: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comment applies 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 this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 16, 2019 letter. Amendment No. 1 to Registration Statement on Form S-1 filed December 30, 2019 Description of Securities, page 25 1.We note your revised disclosure in response to our prior comment 9. Please expand your disclosure to discuss how a voice vote would work for shareholders. For example, please address whether shareholders must attend meetings in person and whether shareholders would receive a proportionate share of the votes based on ownership percentage.
FirstName LastNameLasha Morbedadze Comapany NameExcellerant, Inc. January 10, 2020 Page 2 FirstName LastName Lasha Morbedadze Excellerant, Inc. January 10, 2020 Page 2 You may contact Tracie Mariner at 202-551-3744 or Kevin Kuhar at 202-551-3662 if you have questions regarding comments on the financial statements and related matters. Please contact Jeffrey Gabor at 202-551-2544 or Irene Paik at 202-551-6553 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Robert J. Zepfel, Esq.
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January 10, 2020
Lasha Morbedadze
President, Treasurer, Secretary and Director
Excellerant, Inc.
302 Yayun Ave, Panyu,
Guangzhou, Guangdong 510000, China
Re:Excellerant, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed December 30, 2019
File No. 333-234796
Dear Mr. Morbedadze:
We have reviewed your amended registration statement and have the following comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comment applies 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 this comment, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our December 16, 2019 letter.
Amendment No. 1 to Registration Statement on Form S-1 filed December 30, 2019
Description of Securities, page 25
1.We note your revised disclosure in response to our prior comment 9. Please expand your
disclosure to discuss how a voice vote would work for shareholders. For example, please
address whether shareholders must attend meetings in person and whether shareholders
would receive a proportionate share of the votes based on ownership percentage.
FirstName LastNameLasha Morbedadze
Comapany NameExcellerant, Inc.
January 10, 2020 Page 2
FirstName LastName
Lasha Morbedadze
Excellerant, Inc.
January 10, 2020
Page 2
You may contact Tracie Mariner at 202-551-3744 or Kevin Kuhar at 202-551-3662 if
you have questions regarding comments on the financial statements and related matters. Please
contact Jeffrey Gabor at 202-551-2544 or Irene Paik at 202-551-6553 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Robert J. Zepfel, Esq.