SEC Comment Letter 0000000000-23-001441 to Global Interactive Technologies, Inc. (GITS)
Global Interactive Technologies, Inc.
Date: Feb. 10, 2023 · CIK: 0001911545 · Accession: 0000000000-23-001441
AI Filing Summary & Sentiment
File numbers found in text: 333-269419
Letter
United States securities and exchange commission logo February 10, 2023 Chang-Hyuk Kang Chief Executive Officer Hanryu Holdings, Inc. 160, Yeouiseo-ro Yeongdeungpo-gu, Seoul Republic of Korea 07231 Re:Hanryu Holdings, Inc. Amendment No. 2 to Registration Statement on Form S-1 Filed February 9, 2023 File No. 333-269419 Dear Chang-Hyuk Kang: 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. Amendment No. 2 to Registration Statement on Form S-1 Notes to Condensed Financial Statements Note 3. Restatement, page F-18 1.You state that the amended financial statements amend a previously filed Form S-1 that was not disseminated. Considering all previously filed draft registration statements have been disseminated, revise to clarify or remove this disclosure. Similar revisions should be made elsewhere throughout the filing where you include such statements.
FirstName LastNameChang-Hyuk Kang Comapany NameHanryu Holdings, Inc. February 10, 2023 Page 2 FirstName LastName Chang-Hyuk Kang Hanryu Holdings, Inc. February 10, 2023 Page 2 Notes to Consolidated Financial Statements Note 3. Restatement, page F-64 2.Please revise to include a more fulsome description of the various restatement adjustments to the December 31, 2021 cash flow statement. Ensure that it is clear how each adjustment relates to the Seoul Marina accounting error, or to the extent you are correcting other errors, revise to clearly disclose each item impacting the amended financial statements. You may contact Melissa Kindelan, Senior Staff Accountant, at (202) 551-3564 or Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions regarding comments on the financial statements and related matters. Please contact Edwin Kim, Staff Attorney, at (202) 551-3297 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Matthew Ogurick, Esq.
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United States securities and exchange commission logo
February 10, 2023
Chang-Hyuk Kang
Chief Executive Officer
Hanryu Holdings, Inc.
160, Yeouiseo-ro
Yeongdeungpo-gu, Seoul
Republic of Korea 07231
Re:Hanryu Holdings, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed February 9, 2023
File No. 333-269419
Dear Chang-Hyuk Kang:
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.
Amendment No. 2 to Registration Statement on Form S-1
Notes to Condensed Financial Statements
Note 3. Restatement, page F-18
1.You state that the amended financial statements amend a previously filed Form S-1 that
was not disseminated. Considering all previously filed draft registration statements have
been disseminated, revise to clarify or remove this disclosure. Similar revisions should be
made elsewhere throughout the filing where you include such statements.
FirstName LastNameChang-Hyuk Kang
Comapany NameHanryu Holdings, Inc.
February 10, 2023 Page 2
FirstName LastName
Chang-Hyuk Kang
Hanryu Holdings, Inc.
February 10, 2023
Page 2
Notes to Consolidated Financial Statements
Note 3. Restatement, page F-64
2.Please revise to include a more fulsome description of the various restatement adjustments
to the December 31, 2021 cash flow statement. Ensure that it is clear how each
adjustment relates to the Seoul Marina accounting error, or to the extent you are correcting
other errors, revise to clearly disclose each item impacting the amended financial
statements.
You may contact Melissa Kindelan, Senior Staff Accountant, at (202) 551-3564 or
Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions regarding
comments on the financial statements and related matters. Please contact Edwin Kim, Staff
Attorney, at (202) 551-3297 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Matthew Ogurick, Esq.