SEC Comment Letter 0000000000-23-007698 to SOCIETY PASS INCORPORATED. (SOPA)
SOCIETY PASS INCORPORATED.
Date: July 19, 2023 · CIK: 0001817511 · Accession: 0000000000-23-007698
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-41037
Letter
United States securities and exchange commission logo July 19, 2023 Dennis Nguyen Chief Executive Officer Society Pass Incorporated 701 S. Carson Street Suite 200 Carson City NV 89701 Re:Society Pass Incorporated Form 10-K for Fiscal Year Ended December 31, 2022 Filed March 23, 2023 File No. 001-41037 Dear Dennis Nguyen: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Our comment asks you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2022 Controls and Procedures Management's Report on Internal Control over Financial Reporting, page 106 1.You state you have not included a report of management’s assessment regarding internal control over financial reporting due to a transition period for newly public companies. Note the transition period is applicable until you either had been required to file or filed an annual report for the prior fiscal year. Since you filed an annual report for the previous fiscal year, please amend your filing to include management's assessment regarding internal control over financial reporting. Refer to Item 308(a) of Regulation S-K and instruction 1 to Instructions to Item 308. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameDennis Nguyen Comapany NameSociety Pass Incorporated July 19, 2023 Page 2 FirstName LastName Dennis Nguyen Society Pass Incorporated July 19, 2023 Page 2 You may contact Patrick Kuhn at (202) 551-3308 or Doug Jones at (202) 551-3309 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
July 19, 2023
Dennis Nguyen
Chief Executive Officer
Society Pass Incorporated
701 S. Carson Street Suite 200
Carson City NV 89701
Re:Society Pass Incorporated
Form 10-K for Fiscal Year Ended December 31, 2022
Filed March 23, 2023
File No. 001-41037
Dear Dennis Nguyen:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. Our comment asks you to provide us with
information so we may better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2022
Controls and Procedures
Management's Report on Internal Control over Financial Reporting, page 106
1.You state you have not included a report of management’s assessment regarding internal
control over financial reporting due to a transition period for newly public companies.
Note the transition period is applicable until you either had been required to file or filed an
annual report for the prior fiscal year. Since you filed an annual report for the previous
fiscal year, please amend your filing to include management's assessment regarding
internal control over financial reporting. Refer to Item 308(a) of Regulation S-K and
instruction 1 to Instructions to Item 308.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
FirstName LastNameDennis Nguyen
Comapany NameSociety Pass Incorporated
July 19, 2023 Page 2
FirstName LastName
Dennis Nguyen
Society Pass Incorporated
July 19, 2023
Page 2
You may contact Patrick Kuhn at (202) 551-3308 or Doug Jones at (202) 551-3309 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services