SEC Comment Letter 0000000000-23-006859 to KHEOBA CORP. (KHOB) (CIK 0001909770)
KHEOBA CORP. (KHOB) (CIK 0001909770)
Date: June 27, 2023 · CIK: 0001909770 · Accession: 0000000000-23-006859
AI Filing Summary & Sentiment
File numbers found in text: 333-263020
Letter
United States securities and exchange commission logo June 27, 2023 Gaga Gvenetatdze Chief Executive Officer Kheoba Corp. 24 Vazha-Pshavela St. Tbilisi, Georgia 0105 Re:Kheoba Corp. Amendment No. 4 to Registration Statement on Form S-1 Filed June 21, 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. Unless we note otherwise, our references to prior comments are to comments in our May 31, 2023 letter. Form S-1/A filed June 21, 2023 Notes to Financial Statements Note 3 - Summary of Significant Accounting Policies Website Development Costs, page F-7 1.We note your response to our prior comment 3, however your disclosure does not address when you capitalize website development costs. It also does not state when you start amortizing these costs. Please enhance your disclosure accordingly. Revenue Recognition, page F-7 2.We note your response to our prior comment 2, however, your new disclosure does not address your specific revenue stream. Expand your disclosure to explain what type of
FirstName LastNameGaga Gvenetatdze Comapany NameKheoba Corp. June 27, 2023 Page 2 FirstName LastName Gaga Gvenetatdze Kheoba Corp. June 27, 2023 Page 2 service is included in the sale of your tourism program. Discuss your specific performance obligation, how you determine the transaction price, and when you determine you satisfy the performance obligation. General 3.The auditor consent included in this filing in Exhibit 23.1 refers to Amendment 2 instead of Amendment 4. Please ask your auditors to revise accordingly. 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 27, 2023
Gaga Gvenetatdze
Chief Executive Officer
Kheoba Corp.
24 Vazha-Pshavela St.
Tbilisi, Georgia 0105
Re:Kheoba Corp.
Amendment No. 4 to Registration Statement on Form S-1
Filed June 21, 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. Unless we note
otherwise, our references to prior comments are to comments in our May 31, 2023 letter.
Form S-1/A filed June 21, 2023
Notes to Financial Statements
Note 3 - Summary of Significant Accounting Policies
Website Development Costs, page F-7
1.We note your response to our prior comment 3, however your disclosure does not address
when you capitalize website development costs. It also does not state when you start
amortizing these costs. Please enhance your disclosure accordingly.
Revenue Recognition, page F-7
2.We note your response to our prior comment 2, however, your new disclosure does not
address your specific revenue stream. Expand your disclosure to explain what type of
FirstName LastNameGaga Gvenetatdze
Comapany NameKheoba Corp.
June 27, 2023 Page 2
FirstName LastName
Gaga Gvenetatdze
Kheoba Corp.
June 27, 2023
Page 2
service is included in the sale of your tourism program. Discuss your
specific performance obligation, how you determine the transaction price, and when you
determine you satisfy the performance obligation.
General
3.The auditor consent included in this filing in Exhibit 23.1 refers to Amendment 2 instead
of Amendment 4. Please ask your auditors to revise accordingly.
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