Correspondence 0001213900-25-001784 from RUM Group Inc. (RUM)
RUM Group Inc.
Date: Jan. 7, 2025 · CIK: 0001830081 · Accession: 0001213900-25-001784
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-40079
Referenced dates: January 7, 2025
Letter
VIA EDGAR Division of Corporation Finance Office of Technology Securities and Exchange Commission Re: Rumble Inc. Preliminary Information Statement on Schedule 14C Filed December 31, 2024 File No. 001-40079
Dear Mr. Crispino and Mr. Derby:
On behalf of our client Rumble Inc., a Delaware corporation (the “Company”), we submit to the staff (the “Staff”) of the Securities and Exchange Commission this letter setting forth the Company’s response to the comment letter of the Staff dated January 7, 2025, regarding the Company’s Preliminary Information Statement on Schedule 14C filed on December 31, 2024 (the “Information Statement”). For ease of reference, the Staff’s comment is set forth in bold below, followed by the Company’s response. Concurrently with the submission of this letter, the Company has filed an updated Preliminary Information Statement on Schedule 14C.
Preliminary Information Statement on Schedule 14C
General
1. Please provide the financial information required by Item 13(a) of Schedule 14A or provide your analysis as to why such information is not required. Refer to Item 1 of Schedule 14C and Item 11(e) of Schedule 14A.
In response to the Staff’s comment, the Company has revised page 10 of the Information Statement to incorporate by reference the information required by Item 13(a) of Schedule 14A, as required by Item 1 of Schedule 14C.
Thank you very much for your assistance in this matter. Please do not hesitate to contact Sean M. Ewen of Willkie Farr & Gallagher LLP at (212) 728-8867 with any questions or comments regarding this letter.
Very truly yours,
/s/ Willkie Farr & Gallagher LLP
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CORRESP
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VIA EDGAR
January 7, 2025
Matthew Crispino, Esq.
Matthew Derby, Esq.
Division of Corporation Finance
Office of Technology
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Re:
Rumble Inc.
Preliminary Information Statement on Schedule
14C
Filed December 31, 2024
File No. 001-40079
Dear Mr. Crispino and Mr. Derby:
On behalf of our client Rumble Inc.,
a Delaware corporation (the “Company”), we submit to the staff (the “Staff”) of the Securities and Exchange Commission
this letter setting forth the Company’s response to the comment letter of the Staff dated January 7, 2025, regarding the Company’s
Preliminary Information Statement on Schedule 14C filed on December 31, 2024 (the “Information Statement”). For ease of reference,
the Staff’s comment is set forth in bold below, followed by the Company’s response. Concurrently with the submission of this
letter, the Company has filed an updated Preliminary Information Statement on Schedule 14C.
Preliminary Information Statement on Schedule 14C
General
1. Please provide the financial information required by Item 13(a) of Schedule 14A or provide your analysis as to why such information
is not required. Refer to Item 1 of Schedule 14C and Item 11(e) of Schedule 14A.
In response to the Staff’s comment,
the Company has revised page 10 of the Information Statement to incorporate by reference the information required by Item 13(a) of Schedule
14A, as required by Item 1 of Schedule 14C.
Thank you very much for your assistance
in this matter. Please do not hesitate to contact Sean M. Ewen of Willkie Farr & Gallagher LLP at (212) 728-8867 with any questions
or comments regarding this letter.
Very truly yours,
/s/ Willkie Farr & Gallagher LLP
cc: Michael Ellis, Esq.