SEC Comment Letter 0000000000-23-006013 to MNTN, Inc. (MNTN)
MNTN, Inc.
Date: June 6, 2023 · CIK: 0001891027 · Accession: 0000000000-23-006013
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo June 6, 2023 Mark Douglas Chief Executive Officer MNTN, Inc. 823 Congress Avenue #1827 Austin, TX 78768 Re:MNTN, Inc. Amendment No. 5 to Draft Registration Statement on Form S-1 Submitted May 12, 2023 CIK No. 0001891027 Dear Mark Douglas: We have reviewed your amended draft registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 5 to Draft Registration Statement on Form S-1 Submitted May 12, 2023 Prospectus Summary Competitive Strengths Business Model Allows for High Growth and Profitability, page 5 1.Please revise the profitability aspect of the heading for this paragraph, as well as the related disclosure, to take into account that in recent fiscal years your performance has trended away from, rather than toward, achieving profitability. In this regard, we note your net income/loss results for the fiscal years ended December 31, 2020, 2021 and 2022. Please make conforming revisions in the business section.
FirstName LastNameMark Douglas Comapany NameMNTN, Inc. June 6, 2023 Page 2 FirstName LastName Mark Douglas MNTN, Inc. June 6, 2023 Page 2 Capitalization, page 57 2.Please explain why you did not include the short-term note payable balance of $38,956 as of December 31, 2022, as part of your indebtedness or revise accordingly. You may contact Scott Stringer at 202-551-3272 or Lyn Shenk at 202-551-3380 if you have questions regarding comments on the financial statements and related matters. Please contact Nicholas Nalbantian at 202-551-7470 or Dietrich King at 202-551-8071 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
June 6, 2023
Mark Douglas
Chief Executive Officer
MNTN, Inc.
823 Congress Avenue
#1827
Austin, TX 78768
Re:MNTN, Inc.
Amendment No. 5 to Draft Registration Statement on Form S-1
Submitted May 12, 2023
CIK No. 0001891027
Dear Mark Douglas:
We have reviewed your amended draft registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 5 to Draft Registration Statement on Form S-1 Submitted May 12, 2023
Prospectus Summary
Competitive Strengths
Business Model Allows for High Growth and Profitability, page 5
1.Please revise the profitability aspect of the heading for this paragraph, as well as the
related disclosure, to take into account that in recent fiscal years your performance has
trended away from, rather than toward, achieving profitability. In this regard, we note
your net income/loss results for the fiscal years ended December 31, 2020, 2021 and 2022.
Please make conforming revisions in the business section.
FirstName LastNameMark Douglas
Comapany NameMNTN, Inc.
June 6, 2023 Page 2
FirstName LastName
Mark Douglas
MNTN, Inc.
June 6, 2023
Page 2
Capitalization, page 57
2.Please explain why you did not include the short-term note payable balance of $38,956 as
of December 31, 2022, as part of your indebtedness or revise accordingly.
You may contact Scott Stringer at 202-551-3272 or Lyn Shenk at 202-551-3380 if you
have questions regarding comments on the financial statements and related matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Dietrich King at 202-551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services