SEC Comment Letter 0000000000-24-013052 to Exodus Movement, Inc. (EXOD)
Exodus Movement, Inc.
Date: Nov. 25, 2024 · CIK: 0001821534 · Accession: 0000000000-24-013052
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-56643
Letter
November 25, 2024 James Gernetzke Chief Financial Officer Exodus Movement, Inc. 15418 Weir Street, Suite #333 Omaha, NE 68137 Re:Exodus Movement, Inc. Amendment No. 5 to Registration Statement on Form 10-12G Filed November 13, 2024 File No. 000-56643 Dear James Gernetzke: We have reviewed your amended filing and have the following comments. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response and any amendment you may file in response to this letter, we may have additional comments. Amendment No. 5 to Registration Statement on Form 10-12G Business Our Products and Services New Products, Passkeys, page 5 1.While we note your disclosure that you had no revenue from the Passkeys Wallet for the three months ended September 30, 2024, please tell us whether you had any users of this product as of September 30, 2024. In addition, you disclose that a user's private key is encrypted using an encryption key provided by Exodus. Tell us who holds the encryption key and whether you, as a company or your agent, hold the key (such as on your cloud-based server) or whether the key is held locally on the Exodus app and stored locally on the user's machine.
November 25, 2024 Page 2 KYC and KYB Programs KYB Program For API Providers and Vendors, page 19 2.We note your response to prior comment 5. Please revise your disclosure on page 19 to identify the third-party providers you use for your KYB diligence. 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. Please contact Kate Tillan at 202-551-3604 or David Irving at 202-551-3321 if you have questions regarding comments on the financial statements and related matters. Please contact Sonia Bednarowski at 202-551-3666 or Sandra Hunter Berkheimer at 202-551-3758 with any other questions. Sincerely, Division of Corporation Finance Office of Crypto Assets cc:Thomas J. Kim
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November 25, 2024
James Gernetzke
Chief Financial Officer
Exodus Movement, Inc.
15418 Weir Street, Suite #333
Omaha, NE 68137
Re:Exodus Movement, Inc.
Amendment No. 5 to Registration Statement on Form 10-12G
Filed November 13, 2024
File No. 000-56643
Dear James Gernetzke:
We have reviewed your amended filing and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response and any amendment you may file in response to this
letter, we may have additional comments.
Amendment No. 5 to Registration Statement on Form 10-12G
Business
Our Products and Services
New Products, Passkeys, page 5
1.While we note your disclosure that you had no revenue from the Passkeys Wallet for
the three months ended September 30, 2024, please tell us whether you had any users
of this product as of September 30, 2024. In addition, you disclose that a user's private
key is encrypted using an encryption key provided by Exodus. Tell us who holds the
encryption key and whether you, as a company or your agent, hold the key (such as on
your cloud-based server) or whether the key is held locally on the Exodus app and
stored locally on the user's machine.
November 25, 2024
Page 2
KYC and KYB Programs
KYB Program For API Providers and Vendors, page 19
2.We note your response to prior comment 5. Please revise your disclosure on page 19
to identify the third-party providers you use for your KYB diligence.
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.
Please contact Kate Tillan at 202-551-3604 or David Irving at 202-551-3321 if you
have questions regarding comments on the financial statements and related matters. Please
contact Sonia Bednarowski at 202-551-3666 or Sandra Hunter Berkheimer at 202-551-3758
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:Thomas J. Kim