SEC Comment Letter for Masterworks 009, LLC (CIK 0001806903) — May 21, 2020
Masterworks 009, LLC (CIK 0001806903)
Date: May 21, 2020 · CIK: 0001806903 · Accession: 0000000000-20-004562
AI Filing Summary & Sentiment
File numbers found in text: 024-11185
Letter
United States securities and exchange commission logo May 21, 2020 Joshua B. Goldstein General Counsel Masterworks 009, LLC 497 Broome Street New York, New York 10013 Re:Masterworks 009, LLC Amendment No. 2 to Offering Statement on Form 1-A Filed on May 15, 2020 File No. 024-11185 Dear Mr. Goldstein: We have reviewed your amended 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 amending your offering 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 offering statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our April 30, 2020 letter. Amendment No. 2 to Form 1-A filed on May 15, 2020 Summary Overview, page 4 1.We note your disclosure that "Masterworks, acting as agent for the Company, has agreed to purchase the Painting from a private gallery for $600,000." However, we also note that you have filed an unsigned and undated Form of Art Purchase Agreement as an exhibit and that your disclosures on pages 3 and 61 state that Masterworks "seeks to purchase" the Painting. With a view to understanding the status of the purchase of the artwork, please revise your disclosures to consistently state, if true, that Masterworks has agreed to purchase the Painting.
FirstName LastNameJoshua B. Goldstein Comapany NameMasterworks 009, LLC May 21, 2020 Page 2 FirstName LastName Joshua B. Goldstein Masterworks 009, LLC May 21, 2020 Page 2 You may contact Tony Watson, Staff Accountant at 202-551-3318 or Donna Di Silvio, Staff Accountant at 202-551-3202 if you have questions regarding comments on the financial statements and related matters. Please contact Scott Anderegg, Staff Attorney at 202-551-3342 or Mara Ransom, Office Chief at 202-551-3264 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
May 21, 2020
Joshua B. Goldstein
General Counsel
Masterworks 009, LLC
497 Broome Street
New York, New York 10013
Re:Masterworks 009, LLC
Amendment No. 2 to Offering Statement on Form 1-A
Filed on May 15, 2020
File No. 024-11185
Dear Mr. Goldstein:
We have reviewed your amended 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 amending your offering 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 offering statement and the information you
provide in response to these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our April 30, 2020 letter.
Amendment No. 2 to Form 1-A filed on May 15, 2020
Summary
Overview, page 4
1.We note your disclosure that "Masterworks, acting as agent for the Company, has agreed
to purchase the Painting from a private gallery for $600,000." However, we also note that
you have filed an unsigned and undated Form of Art Purchase Agreement as an exhibit
and that your disclosures on pages 3 and 61 state that Masterworks "seeks to purchase" the
Painting. With a view to understanding the status of the purchase of the artwork, please
revise your disclosures to consistently state, if true, that Masterworks has agreed to
purchase the Painting.
FirstName LastNameJoshua B. Goldstein
Comapany NameMasterworks 009, LLC
May 21, 2020 Page 2
FirstName LastName
Joshua B. Goldstein
Masterworks 009, LLC
May 21, 2020
Page 2
You may contact Tony Watson, Staff Accountant at 202-551-3318 or Donna Di Silvio,
Staff Accountant at 202-551-3202 if you have questions regarding comments on the financial
statements and related matters. Please contact Scott Anderegg, Staff Attorney at 202-551-3342
or Mara Ransom, Office Chief at 202-551-3264 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services