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SEC Comment Letter 0000000000-24-013385 to Exodus Movement, Inc. (EXOD)

Exodus Movement, Inc.
Date: Dec. 4, 2024 · CIK: 0001821534 · Accession: 0000000000-24-013385

Regulatory Compliance Financial Reporting Business Model Clarity

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File numbers found in text: 000-56643

Date
December 4, 2024
Author
James Gernetzke
Form
UPLOAD
Company
Exodus Movement, Inc.

Letter

December 4, 2024 James Gernetzke Chief Financial Officer Exodus Movement, Inc. 15418 Weir Street, Suite #333 Omaha, NE 68137 Re:Exodus Movement, Inc. Amendment No. 6 to Registration Statement on Form 10-12G Filed November 27, 2024 File No. 000-56643 Dear James Gernetzke: We have reviewed your amended filing and have the following comment. 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. Amendment No. 6 to Registration Statement on Form 10-12G General 1.Please confirm your understanding in writing that: •our decision not to issue additional comments should not be interpreted to mean that we either agree or disagree with your disclosure or responses, or, with respect to your business operations, any conclusions you have made, positions you have taken, or practices you have engaged in or may engage in. •completing our review of the filing does not foreclose the Commission from taking any action or advancing any position with respect to the filing, the company, or the company’s practices.

December 4, 2024 Page 2 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

Show Raw Text
December 4, 2024
James Gernetzke
Chief Financial Officer
Exodus Movement, Inc.
15418 Weir Street, Suite #333
Omaha, NE 68137
Re:Exodus Movement, Inc.
Amendment No. 6 to Registration Statement on Form 10-12G
Filed November 27, 2024
File No. 000-56643
Dear James Gernetzke:
            We have reviewed your amended filing and have the following comment.
            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.
Amendment No. 6 to Registration Statement on Form 10-12G
General
1.Please confirm your understanding in writing that:
•our decision not to issue additional comments should not be interpreted to mean
that we either agree or disagree with your disclosure or responses, or, with respect
to your business operations, any conclusions you have made, positions you have
taken, or practices you have engaged in or may engage in.
•completing our review of the filing does not foreclose the Commission from
taking any action or advancing any position with respect to the filing, the
company, or the company’s practices.

December 4, 2024
Page 2
            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