SEC Comment Letter 0000000000-23-006399 to KHEOBA CORP. (KHOB) (CIK 0001909770)
KHEOBA CORP. (KHOB) (CIK 0001909770)
Date: June 14, 2023 · CIK: 0001909770 · Accession: 0000000000-23-006399
AI Filing Summary & Sentiment
File numbers found in text: 333-263020
Letter
United States securities and exchange commission logo June 14, 2023 Gaga Gvenetatdze Chief Executive Officer Kheoba Corp. 24 Vazha-Pshavela St. Tbilisi, Georgia 0105 Re:Kheoba Corp. Amendment No. 3 to Registration Statement on Form S-1 Filed May 31, 2023 File No. 333-263020 Dear Gaga Gvenetatdze: We have reviewed your amended 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 amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Form S-1/A filed May 31, 2023 Report of Independent Accounting Firm, page F-1 1.We note the report of your independent accounting firm is not signed. Please amend to include a signed report. Notes to the Financial Statements Note 3 - Summary of Significant Accounting Policies, page F-6 2.We note you generated revenue for the year ended October 31, 2023 and the six months ended April 30, 2023. Please include a revenue recognition footnote that is specific to your business, including disclosing your performance obligation(s) and timing of revenue recognition.
FirstName LastNameGaga Gvenetatdze Comapany NameKheoba Corp. June 14, 2023 Page 2 FirstName LastName Gaga Gvenetatdze Kheoba Corp. June 14, 2023 Page 2 3.We note you recorded website development expense. Please disclose your accounting policy as it relates to website development costs. You may contact Inessa Kessman, Senior Staff Accountant, at (202) 551-3371 or Robert Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact Marion Graham, Staff Attorney, at (202) 551-6521 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other questions. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
June 14, 2023
Gaga Gvenetatdze
Chief Executive Officer
Kheoba Corp.
24 Vazha-Pshavela St.
Tbilisi, Georgia 0105
Re:Kheoba Corp.
Amendment No. 3 to Registration Statement on Form S-1
Filed May 31, 2023
File No. 333-263020
Dear Gaga Gvenetatdze:
We have reviewed your amended 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 amending your registration statement and providing the
requested information. 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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form S-1/A filed May 31, 2023
Report of Independent Accounting Firm, page F-1
1.We note the report of your independent accounting firm is not signed. Please amend to
include a signed report.
Notes to the Financial Statements
Note 3 - Summary of Significant Accounting Policies, page F-6
2.We note you generated revenue for the year ended October 31, 2023 and the six months
ended April 30, 2023. Please include a revenue recognition footnote that is specific to
your business, including disclosing your performance obligation(s) and timing of revenue
recognition.
FirstName LastNameGaga Gvenetatdze
Comapany NameKheoba Corp.
June 14, 2023 Page 2
FirstName LastName
Gaga Gvenetatdze
Kheoba Corp.
June 14, 2023
Page 2
3.We note you recorded website development expense. Please disclose your accounting
policy as it relates to website development costs.
You may contact Inessa Kessman, Senior Staff Accountant, at (202) 551-3371 or Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters. Please contact Marion Graham, Staff
Attorney, at (202) 551-6521 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology