SecProbe.io

Filing text and metadata
Intelligence Terminal Search Topics Monthly Activity About

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

Date
December 22, 2023
Author
/s/
Form
CORRESP
Company
Tradewinds Universal (CIK 0001916558)

Letter

Via EDGAR Division of Corporation Finance Office of Manufacturing Attention: Eranga Dias 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

Show Raw Text
CORRESP
1
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