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SEC Company Response from Collectable Sports Assets, LLC (CIK 0001804446) — Jul 19, 2022

Collectable Sports Assets, LLC (CIK 0001804446)
Date: July 19, 2022 · CIK: 0001804446 · Accession: 0001829126-22-014468

AI Filing Summary & Sentiment

File numbers found in text: 024-11178

Date
May 31, 2022
Author
Collectable
Form
CORRESP
Company
Collectable Sports Assets, LLC (CIK 0001804446)

Letter

Collectable Sports Assets, LLC

Westchester Avenue

Suite W21000

White Plains, NY 10604

July 19, 2022

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC. 20549

Attn: Jennie Beysolow

Re: Collectable Sports Assets, LLC

Offering Statement on Form 1-A

Post-qualification Amendment No. 21

Filed: May 31, 2022

File No. 024-11178

Ladies and Gentlemen:

Reference is made to the June 30, 2022 letter (the “Comment Letter”) from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) to Collectable Sports Assets, LLC (the “Company”) with respect to the Company’s Post-Qualification Amendment No. 21 (“POS #21”) to its Offering Statement on Form 1-A (the “Offering Statement”) and the Company’s July 5, 2022 letter (the “Response Letter”), responding to the Comment Letter.

Subsequent to our submission of the Response Letter, we understand that Ms. Beysolow had a conversation with our counsel, Gary M. Brown, in which Ms. Beysolow advised Mr. Brown that the Commission and Staff were firm in their position as set forth in the Comment Letter. Accordingly, in the interest of having the remaining offerings added to the Offering Statement by POS #21 qualified without further delay, we have contemporaneously with this letter filed Post-Qualification Amendment No. 22 (“POS #22) to the Offering Statement. POS #22 removes all of the “blind pool” offerings (and related disclosures) from the Offering Statement – this addresses Comment #1 in the Comment Letter. POS #22 also fixes the offering price of all of the offerings in the Offering Statement, which addresses Comment #2 in the Comment Letter.

We trust that these actions taken in response to the Staff’s comment are sufficient to allow the Staff to expeditiously qualify POS #22, which we request be done as soon as practicable. Please be advised that our taking the actions described above does not necessarily indicate our agreement with the Staff’s position as set forth in the Comment Letter and we reserve the right to have further discussions about this matter with the Staff in order to be able to be able to make future “blind pool” offerings in the manner proposed in POS #21.

We would be pleased to discuss this response with the Staff if you believe that is necessary or desirable. Please feel free to contact the undersigned at (858) 245-2955 or our counsel, Gary M. Brown at (615) 390-7230. Again – we reiterate our request that POS #22 be qualified as soon as practicable.

Sincerely,
Collectable
Sports Assets, LLC

Show Raw Text
CORRESP
1
filename1.htm

Collectable
Sports Assets, LLC

333
Westchester Avenue

Suite
W21000

White
Plains, NY 10604

July
19, 2022

U.S.
Securities and Exchange Commission

100 F Street, N.E.

Washington, DC. 20549

Attn: Jennie Beysolow

    Re:
    Collectable
    Sports Assets, LLC

    Offering
                                            Statement on Form 1-A

    Post-qualification
    Amendment No. 21

    Filed:
    May 31, 2022

    File
    No. 024-11178

Ladies
and Gentlemen:

Reference
is made to the June 30, 2022 letter (the “Comment Letter”) from the staff (the “Staff”) of the
U.S. Securities and Exchange Commission (the “Commission”) to Collectable Sports Assets, LLC (the “Company”)
with respect to the Company’s Post-Qualification Amendment No. 21 (“POS #21”) to its Offering Statement on Form
1-A (the “Offering Statement”) and the Company’s July 5, 2022 letter (the “Response Letter”),
responding to the Comment Letter.

Subsequent
to our submission of the Response Letter, we understand that Ms. Beysolow had a conversation with our counsel, Gary M. Brown, in which
Ms. Beysolow advised Mr. Brown that the Commission and Staff were firm in their position as set forth in the Comment Letter. Accordingly,
in the interest of having the remaining offerings added to the Offering Statement by POS #21 qualified without further delay, we have
contemporaneously with this letter filed Post-Qualification Amendment No. 22 (“POS #22) to the Offering Statement. POS #22
removes all of the “blind pool” offerings (and related disclosures) from the Offering Statement – this addresses Comment
#1 in the Comment Letter. POS #22 also fixes the offering price of all of the offerings in the Offering Statement, which addresses Comment
#2 in the Comment Letter.

We
trust that these actions taken in response to the Staff’s comment are sufficient to allow the Staff to expeditiously qualify POS
#22, which we request be done as soon as practicable. Please be advised that our taking the actions described above does not necessarily
indicate our agreement with the Staff’s position as set forth in the Comment Letter and we reserve the right to have further discussions
about this matter with the Staff in order to be able to be able to make future “blind pool” offerings in the manner proposed
in POS #21.

We
would be pleased to discuss this response with the Staff if you believe that is necessary or desirable.  Please feel free to contact
the undersigned at (858) 245-2955 or our counsel, Gary M. Brown at (615) 390-7230. Again – we reiterate our request that POS #22
be qualified as soon as practicable.

    Sincerely,

    Collectable
    Sports Assets, LLC

    By:
    CS Asset Manager, LLC, its managing member

    By:

    /s/
    Jarod Winters

    Jarod
    Winters

    COO

    cc:
    Gary
    M. Brown