SEC Comment Letter for SavvyShares LLC (CIK 0001801255) — Apr 6, 2020
SavvyShares LLC (CIK 0001801255)
Date: April 6, 2020 · CIK: 0001801255 · Accession: 0000000000-20-002936
AI Filing Summary & Sentiment
Letter
April 3, 2020 Rosanne Luth Chief Executive Officer SavvyShares LLC 1365 Fourth Avenue San Diego, CA 92101 Re:SavvyShares LLC Amendment No. 1 to Draft Offering Statement on Form 1-A Submitted March 23, 2020 CIK No. 0001801255 Dear Ms. Luth: We have reviewed your amended draft offering statement and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by providing the requested information and either submitting an amended draft offering statement or publicly filing your offering statement on EDGAR. 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 draft offering statement or filed offering statement and the information you provide in response to this comment, we may have additional comments. Amendment No. 1 to Draft Offering Statement on Form 1-A Description of Business Competition, page 26 1.You disclose that you believe your single-source digital tracking technology will provide you with a competitive advantage. In this regard, we note from your website that Luth Research, your founder and competitor, has comparable tracking technology ("SavvyConnect") that it launched in 2009. If true, please identify Luth Research as a competitor in digital tracking and address the risks and challenges that you may face as a result of such competition.
FirstName LastNameRosanne Luth Comapany NameSavvyShares LLC April 3, 2020 Page 2 FirstName LastName Rosanne Luth SavvyShares LLC April 3, 2020 Page 2 You may contact Eiko Yaoita Pyles, Staff Accountant, at (202) 551-3587 or Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions regarding comments on the financial statements and related matters. Please contact Bernard Nolan, Attorney-Adviser, (202) 551-6515 or, in his absence, Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: John Tishler, Esq.
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April 3, 2020
Rosanne Luth
Chief Executive Officer
SavvyShares LLC
1365 Fourth Avenue
San Diego, CA 92101
Re:SavvyShares LLC
Amendment No. 1 to Draft Offering Statement on Form 1-A
Submitted March 23, 2020
CIK No. 0001801255
Dear Ms. Luth:
We have reviewed your amended draft offering statement and have the following
comment. In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter by providing the requested information and either submitting
an amended draft offering statement or publicly filing your offering statement on EDGAR. 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 draft offering statement or filed offering statement and the information you provide in
response to this comment, we may have additional comments.
Amendment No. 1 to Draft Offering Statement on Form 1-A
Description of Business
Competition, page 26
1.You disclose that you believe your single-source digital tracking technology will provide
you with a competitive advantage. In this regard, we note from your website that Luth
Research, your founder and competitor, has comparable tracking technology
("SavvyConnect") that it launched in 2009. If true, please identify Luth Research as a
competitor in digital tracking and address the risks and challenges that you may face as a
result of such competition.
FirstName LastNameRosanne Luth
Comapany NameSavvyShares LLC
April 3, 2020 Page 2
FirstName LastName
Rosanne Luth
SavvyShares LLC
April 3, 2020
Page 2
You may contact Eiko Yaoita Pyles, Staff Accountant, at (202) 551-3587 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions regarding comments
on the financial statements and related matters. Please contact Bernard Nolan, Attorney-Adviser,
(202) 551-6515 or, in his absence, Jan Woo, Legal Branch Chief, at (202) 551-3453 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: John Tishler, Esq.