SEC Comment Letter 0000000000-23-007631 to KHEOBA CORP. (KHOB) (CIK 0001909770)
KHEOBA CORP. (KHOB) (CIK 0001909770)
Date: July 18, 2023 · CIK: 0001909770 · Accession: 0000000000-23-007631
AI Filing Summary & Sentiment
File numbers found in text: 333-263020
Letter
United States securities and exchange commission logo July 18, 2023 Gaga Gvenetatdze Chief Executive Officer Kheoba Corp. 24 Vazha-Pshavela St. Tbilisi, Georgia 0105 Re:Kheoba Corp. Amendment No. 5 to Registration Statement on Form S-1 Filed July 6, 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 June 27, 2023 letter. Amendment No. 5 to Registration Statement on Form S-1 Notes to the Financial Statements Note 3 - Summary of Significant Accounting Policies Revenue Recognition, page F-7 1.We note your response to our prior comment 2 and the new disclosure on page F-7. In your disclosure you state, "The Company determines that the obligation is satisfied when the customer signs the act of acceptance." In this regard, disclose if revenue is recognized at a point in time or over time and tell us how you considered ASC 606-10-25-27(a) when determining revenue recognition timing.
FirstName LastNameGaga Gvenetatdze Comapany NameKheoba Corp. July 18, 2023 Page 2 FirstName LastName Gaga Gvenetatdze Kheoba Corp. July 18, 2023 Page 2 Website Development Costs, page F-7 2.We note your response to comment 1 and new disclosure on page F-15. However, your disclosure still does not address when you start to capitalize website development costs and when you determine to begin amortization. Please revise your disclosure and refer to your basis in the accounting literature. Also, tell us why you have not recorded amortization expense for six months ended April 30, 2023. 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
July 18, 2023
Gaga Gvenetatdze
Chief Executive Officer
Kheoba Corp.
24 Vazha-Pshavela St.
Tbilisi, Georgia 0105
Re:Kheoba Corp.
Amendment No. 5 to Registration Statement on Form S-1
Filed July 6, 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 June 27, 2023 letter.
Amendment No. 5 to Registration Statement on Form S-1
Notes to the Financial Statements
Note 3 - Summary of Significant Accounting Policies
Revenue Recognition, page F-7
1.We note your response to our prior comment 2 and the new disclosure on page F-7. In
your disclosure you state, "The Company determines that the obligation is satisfied when
the customer signs the act of acceptance." In this regard, disclose if revenue is recognized
at a point in time or over time and tell us how you considered ASC 606-10-25-27(a) when
determining revenue recognition timing.
FirstName LastNameGaga Gvenetatdze
Comapany NameKheoba Corp.
July 18, 2023 Page 2
FirstName LastName
Gaga Gvenetatdze
Kheoba Corp.
July 18, 2023
Page 2
Website Development Costs, page F-7
2.We note your response to comment 1 and new disclosure on page F-15. However, your
disclosure still does not address when you start to capitalize website development costs
and when you determine to begin amortization. Please revise your disclosure and refer to
your basis in the accounting literature. Also, tell us why you have not recorded
amortization expense for six months ended April 30, 2023.
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