SEC Company Response from Commonwealth Thoroughbreds LLC (CIK 0001789339) — Sep 20, 2021
Commonwealth Thoroughbreds LLC (CIK 0001789339)
Date: Sept. 20, 2021 · CIK: 0001789339 · Accession: 0001437749-21-022437
AI Filing Summary & Sentiment
File numbers found in text: 024-11130
Referenced dates: September 20, 2021
Letter
comm20210920_corresp.htm
Frost Brown Todd LLC
400 West Market Street, 32nd Floor
Louisville, Kentucky 40222
September 21, 2021
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549-4561
Attention: Taylor Beech
Office of Trade & Services
Re: Commonwealth Thoroughbreds LLC
Post-Qualification Amendment No. 3 to Offering Statement on Form 1-A
Filed September 3, 2021
File No. 024-11130
Ladies and Gentlemen:
On behalf of Commonwealth Thoroughbreds LLC (“Commonwealth” or the “Company”), we hereby submit this response to the following comment in the letter from the Commission’s staff dated September 20, 2021.
Post-Qualification Amendment No. 3 to Offering Statement on Form 1-A
General
1.
Your disclosure appears to suggest that sales of your Series OL2018 did not commence within two calendar days of that series' qualification date of March 30, 2020. In this regard, we note your disclosure on page 69 that "the commencement of the Series OL2018 offering [was] on May 1, 2020." To comply with Rule 251(d)(3)(i)(F) of Regulation A, you must commence the offering of each series you qualify within two calendar days of qualification. Commencing the offering of some of the qualified series while delaying the offering of others results in an impermissible delayed offering of the delayed series under Rule 251(d)(3)(i)(F). Please confirm that you will commence the offering of each series you qualify within two calendar days of qualification.
Response:
Commonwealth Thoroughbreds LLC confirms that it will commence the offering of each series the Company qualifies within two calendar days of qualification.
Please call me at (502) 568-0277 if you have any questions or require any further information with respect to these matters.
Sincerely,
FROST BROWN TODD LLC
Show Raw Text
CORRESP 1 filename1.htm comm20210920_corresp.htm Frost Brown Todd LLC 400 West Market Street, 32nd Floor Louisville, Kentucky 40222 September 21, 2021 Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, DC 20549-4561 Attention: Taylor Beech Office of Trade & Services Re: Commonwealth Thoroughbreds LLC Post-Qualification Amendment No. 3 to Offering Statement on Form 1-A Filed September 3, 2021 File No. 024-11130 Ladies and Gentlemen: On behalf of Commonwealth Thoroughbreds LLC (“Commonwealth” or the “Company”), we hereby submit this response to the following comment in the letter from the Commission’s staff dated September 20, 2021. Post-Qualification Amendment No. 3 to Offering Statement on Form 1-A General 1. Your disclosure appears to suggest that sales of your Series OL2018 did not commence within two calendar days of that series' qualification date of March 30, 2020. In this regard, we note your disclosure on page 69 that "the commencement of the Series OL2018 offering [was] on May 1, 2020." To comply with Rule 251(d)(3)(i)(F) of Regulation A, you must commence the offering of each series you qualify within two calendar days of qualification. Commencing the offering of some of the qualified series while delaying the offering of others results in an impermissible delayed offering of the delayed series under Rule 251(d)(3)(i)(F). Please confirm that you will commence the offering of each series you qualify within two calendar days of qualification. Response: Commonwealth Thoroughbreds LLC confirms that it will commence the offering of each series the Company qualifies within two calendar days of qualification. Please call me at (502) 568-0277 if you have any questions or require any further information with respect to these matters. Sincerely, FROST BROWN TODD LLC /s/ Alan K. MacDonald, Member Securities and Exchange Commission Page 2 cc: Brian Doxtator Chief Executive Officer Commonwealth Thoroughbreds LLC