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UPLOAD Filing

Global Innovative Platforms Inc.
Date: April 18, 2025 · CIK: 0001837774 · Accession: 0000000000-25-004133

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File numbers found in text: 024-12570

Date
April 18, 2025
Author
Division of
Form
UPLOAD
Company
Global Innovative Platforms Inc.

Letter

Re: Global Innovative Platforms Inc. Amendment No. 1 to Offering Circular on Form 1-A Filed April 4, 2025 File No. 024-12570 Dear Andrew Brown:

April 18, 2025

Andrew Brown Chief Executive Officer Global Innovative Platforms Inc. 149 James Place Orlando, FL 32751

We have reviewed your amended offering statement and have the following comment(s).

Please respond to this letter by amending your offering statement and providing the requested information. If you do not believe a 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 this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our March 10, 2025 letter.

Amendment No. 1 to Offering Statement on Form 1-A Plan of Distribution, page 16

1. We note your response to prior comment 6 and your disclosure that "[w]e expect the initial closing to occur within 90 days from the qualification of this offering by the SEC, provided the minimum offering amount is achieved." Revise to reconcile with your cover page disclosure that "[t]his offering is being conducted on a best-efforts basis, which means that there is no minimum number of Offered Shares that must be sold by us for this offering to close . . . ." To the extent you continue to expect the initial closing to take place up to 90 days after qualification, please revise to explain why you expect to need such time period to complete an initial closing. April 18, 2025 Page 2 Overview, page 25

2. We note the graphic added to page 28. Please revise to describe what this graphic depicts, whether it relates to your proof-of-concept study or the study conducted in October of 2024, and whether these are different studies. To the extent they are different studies, please also revise to provide more detail concerning your proof-of- concept study. Business Heartworm Breath Test, page 30

3. We note your response to prior comment 12 and your disclosure on page 31: "The Breath Capture Device has been proven to adequately provide the appropriate amount of breath for a sample to be appropriately analyzed by the VOCAM Plus and the FROG." Please revise to provide support for your statement that the Breath Capture Device is "proven." If the support is your October 2024 study with eight samples then please revise to note the limited sample size. Business Our Competitive Strengths, page 32

4. We note your revised disclosure that "[you] will be researching the ability to identify potentially toxic environmental conditions for a multitude of animals." Please revise your disclosure to discuss the timeline to begin research and the conditions and animals you plan to study, if known. Intellectual Property, page 37

5. We note your revised disclosure in response to our prior comment 8 and reissue it in part. Please revise your disclosure to provide the expiration dates and type of patent protection for each patent listed. We note certain patents include method or process descriptions.

Please contact Robert Augustin at 202-551-8483 or Margaret Sawicki at 202-551- 7153 with any other questions.

Sincerely,
Division of
Corporation Finance
Office of
Industrial Applications and
Services
cc: Stephen M. Fleming

Show Raw Text
<DOCUMENT>
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<TEXT>
 April 18, 2025

Andrew Brown
Chief Executive Officer
Global Innovative Platforms Inc.
149 James Place
Orlando, FL 32751

 Re: Global Innovative Platforms Inc.
 Amendment No. 1 to Offering Circular on Form 1-A
 Filed April 4, 2025
 File No. 024-12570
Dear Andrew Brown:

 We have reviewed your amended offering statement and have the following
comment(s).

 Please respond to this letter by amending your offering statement and
providing the
requested information. If you do not believe a 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 this letter, we may have additional comments. Unless we
note
otherwise, any references to prior comments are to comments in our March 10,
2025 letter.

Amendment No. 1 to Offering Statement on Form 1-A
Plan of Distribution, page 16

1. We note your response to prior comment 6 and your disclosure that "[w]e
expect the
 initial closing to occur within 90 days from the qualification of this
offering by the
 SEC, provided the minimum offering amount is achieved." Revise to
reconcile with
 your cover page disclosure that "[t]his offering is being conducted on a
best-efforts
 basis, which means that there is no minimum number of Offered Shares
that must be
 sold by us for this offering to close . . . ." To the extent you
continue to expect the
 initial closing to take place up to 90 days after qualification, please
revise to explain
 why you expect to need such time period to complete an initial closing.
 April 18, 2025
Page 2
Overview, page 25

2. We note the graphic added to page 28. Please revise to describe what
this graphic
 depicts, whether it relates to your proof-of-concept study or the study
conducted in
 October of 2024, and whether these are different studies. To the extent
they are
 different studies, please also revise to provide more detail concerning
your proof-of-
 concept study.
Business
Heartworm Breath Test, page 30

3. We note your response to prior comment 12 and your disclosure on page
31: "The
 Breath Capture Device has been proven to adequately provide the
appropriate amount
 of breath for a sample to be appropriately analyzed by the VOCAM Plus
and the
 FROG." Please revise to provide support for your statement that the
Breath Capture
 Device is "proven." If the support is your October 2024 study with eight
samples then
 please revise to note the limited sample size.
Business
Our Competitive Strengths, page 32

4. We note your revised disclosure that "[you] will be researching the
ability to identify
 potentially toxic environmental conditions for a multitude of animals."
Please revise
 your disclosure to discuss the timeline to begin research and the
conditions and
 animals you plan to study, if known.
Intellectual Property, page 37

5. We note your revised disclosure in response to our prior comment 8 and
reissue it in
 part. Please revise your disclosure to provide the expiration dates and
type of patent
 protection for each patent listed. We note certain patents include
method or process
 descriptions.

 Please contact Robert Augustin at 202-551-8483 or Margaret Sawicki at
202-551-
7153 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Industrial Applications and
 Services
cc: Stephen M. Fleming
</TEXT>
</DOCUMENT>