Correspondence 0001079973-24-000427 from Tradewinds Universal (CIK 0001916558) (TRWD)
Tradewinds Universal (CIK 0001916558)
Date: March 25, 2024 · CIK: 0001916558 · Accession: 0001079973-24-000427
AI Filing Summary & Sentiment
File numbers found in text: 333-276233
Referenced dates: February 27, 2024
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CORRESP
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filename1.htm
Tradewinds
Universal
501
Mercury Lane
Brea, CA. 92821
855-434-4488
TradewindsUniversal.com
Andrewreadtw@gmail.com
March
25, 2024
Via
EDGAR
Division
of Corporation Finance
Office
of Manufacturing
U.S.
SECURITIES AND EXCHANGE COMMISSION
100
F Street, N.E.
Washington,
DC 20549
Attention: Eranga Dias
Geoffrey Kruczek
RE: Tradewinds Universal
Registration Statement on Form S-1
Filed December 22, 2023
File No. 333-276233
Dear
Ms. Dias and Mr. Kruczek:
We
are hereby responding to the letter dated February 27, 2024 (the“Comment Letter”) from the staff (the “Staff”)
of the Securities and Exchange Commission regarding the Company’s Amendment No. 1 to S-1 Registration Statement Filed on February
14, 2024, File No. 333-276233.
For
ease of reference, the text of the Staff’s comment is included in boldface type below, followed by the Company’s response.
Amendment
1 to Registration Statement on Form S-1 Filed February 14, 2024 Certain Relationships, page 22
1.
We note your response to prior comment 2; however, the first two bullets of this section continue to use transaction thresholds that
are inconsistent with the requirements of Item 404(d) of Regulation S-K. Please revise.
Response
The section referred to is revised according to your comments.
General
2.
We reissue previous comment 5 in its entirety. Please revise your management's discussion and analysis section according to previous
comment 5 and identify the revisions made.
Response:
We have revised the Management’s Discussion and Analysis of Financial Condition and Results of Operations section in its entirety.
3.
We note your response to previous comment 6 and reissue comment 6. Please revise your disclosure to fully address the comment, including,
but not limited to, describing the material terms of your agreement with the third party who conducts the manufacturing. Also clarify
what you mean by the statement that you are "currently in production" for the manufacturing of your product.
Response:
We have revised the Management’s Discussion and Analysis of Financial Condition and Results of Operations section in its entirety
per your comments.
Sincerely,
/s/
Andrew Read
President,
Tradewinds Universal