SEC Comment Letter 0000000000-22-012389 to SYNTEC OPTICS HOLDINGS, INC. (OPTX)
SYNTEC OPTICS HOLDINGS, INC.
Date: Nov. 15, 2022 · CIK: 0001866816 · Accession: 0000000000-22-012389
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-41034
Letter
United States securities and exchange commission logo November 15, 2022 Al Kapoor Chief Executive Officer OmniLit Acquisition Corp. 1111 Lincoln Road, Suite 500 Miami Beach, FL 33139 Re:OmniLit Acquisition Corp. Preliminary Proxy Statement on Schedule 14A Filed November 9, 2022 File No. 001-41034 Dear Al Kapoor: We have reviewed your filing and have the following comment. In our comment, we may ask 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 and any amendment you may file in response to this comment, we may have additional comments. Preliminary Proxy Statement on Schedule 14A filed November 9, 2022 General 1.With a view toward disclosure, please tell us whether your sponsor is, is controlled by, or has substantial ties with a non-U.S. person. If so, also include risk factor disclosure that addresses how this fact could impact your ability to complete your initial business combination. For instance, discuss the risk to investors that you may not be able to complete an initial business combination with a U.S. target company should the transaction be subject to review by a U.S. government entity, such as the Committee on Foreign Investment in the United States (CFIUS), or ultimately prohibited. Disclose that as a result, the pool of potential targets with which you could complete an initial business combination may be limited. Further, disclose that the time necessary for government review of the transaction or a decision to prohibit the transaction could prevent you from completing an initial business combination and require you to liquidate. Disclose the consequences of liquidation to investors, such as the losses of the investment opportunity
FirstName LastNameAl Kapoor Comapany NameOmniLit Acquisition Corp. November 15, 2022 Page 2 FirstName LastName Al Kapoor OmniLit Acquisition Corp. November 15, 2022 Page 2 in a target company, any price appreciation in the combined company, and the warrants, which would expire worthless. 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 Melanie Singh at 202-551-4074 or Maryse Mills-Apenteng at 202-551- 3457 if you have any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Christopher J. Capuzzi, Esq.
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United States securities and exchange commission logo
November 15, 2022
Al Kapoor
Chief Executive Officer
OmniLit Acquisition Corp.
1111 Lincoln Road, Suite 500
Miami Beach, FL 33139
Re:OmniLit Acquisition Corp.
Preliminary Proxy Statement on Schedule 14A
Filed November 9, 2022
File No. 001-41034
Dear Al Kapoor:
We have reviewed your filing and have the following comment. In our comment, we
may ask 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 and any amendment you may file in response to this
comment, we may have additional comments.
Preliminary Proxy Statement on Schedule 14A filed November 9, 2022
General
1.With a view toward disclosure, please tell us whether your sponsor is, is controlled by, or
has substantial ties with a non-U.S. person. If so, also include risk factor disclosure that
addresses how this fact could impact your ability to complete your initial business
combination. For instance, discuss the risk to investors that you may not be able to
complete an initial business combination with a U.S. target company should the
transaction be subject to review by a U.S. government entity, such as the Committee on
Foreign Investment in the United States (CFIUS), or ultimately prohibited. Disclose that
as a result, the pool of potential targets with which you could complete an initial business
combination may be limited. Further, disclose that the time necessary for government
review of the transaction or a decision to prohibit the transaction could prevent you from
completing an initial business combination and require you to liquidate. Disclose the
consequences of liquidation to investors, such as the losses of the investment opportunity
FirstName LastNameAl Kapoor
Comapany NameOmniLit Acquisition Corp.
November 15, 2022 Page 2
FirstName LastName
Al Kapoor
OmniLit Acquisition Corp.
November 15, 2022
Page 2
in a target company, any price appreciation in the combined company, and the warrants,
which would expire worthless.
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 Melanie Singh at 202-551-4074 or Maryse Mills-Apenteng at 202-551-
3457 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Christopher J. Capuzzi, Esq.