Correspondence 0001731122-22-001979 from Innovation Beverage Group Ltd (IBG) (CIK 0001924482) (IBG)
Innovation Beverage Group Ltd (IBG) (CIK 0001924482)
Date: Nov. 14, 2022 · CIK: 0001924482 · Accession: 0001731122-22-001979
AI Filing Summary & Sentiment
File numbers found in text: 333-266965
Letter
Securities and Exchange Commission Division of Corporate Finance Re: Innovation Beverage Group Ltd Amendment No. 8 to the Registration Statement on Form F-1 File No. 333-266965 Filed November 15, 2022
Dear Ms. Haywood and Mr. Ewing:
Innovation Beverage Group Ltd (the “Company” or “IBG”) previously submitted Amendment No. 7 to the Company’s Registration Statement on Form F-1 (the “Registration Statement”) pursuant to Title I, Section 106 under the Jumpstart Our Business Startups Act with the Securities and Exchange Commission (the “Commission”) on October 25, 2022. Amendment No. 8 responds to the comment letter received on November 4, 2022 from the staff of the Commission (the “Staff”). For ease of review, we have set forth below the comment of your letter followed by the Company’s response thereto.
Risk Factors, page 16
1. We note recent instances of extreme stock price run-ups followed by rapid price declines and stock price volatility seemingly unrelated to company performance following a number of recent initial public offerings, particularly among companies with relatively smaller public floats. Revise to include a separate risk factor addressing the potential for rapid and substantial price volatility and any known factors particular to your offering that may add to this risk and discuss the risks to investors when investing in stock where the price is changing rapidly. Clearly state that such volatility, including any stock-run up, may be unrelated to your actual or expected operating performance and financial condition or prospects, making it difficult for prospective investors to assess the rapidly changing value of your stock.
Response: The Company acknowledges the Staff’s comment and has made the requested revision on page 32. Please see the risk factor titled, “The market price of our ordinary shares and warrants may be highly volatile, and you could lose all or part of your investment.”
Should you have any questions regarding the foregoing, please do not hesitate to contact the Company’s counsel, Darrin Ocasio, of Sichenzia Ross Ference LLP at (212) 930-9700.
Sincerely,
Dean Huge
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Innovation Beverage Group Limited
29 Anvil Road
Seven Hills, NSW 2147
Australia
November 15, 2022
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Sherry Haywood and Evan Ewing
Re:
Innovation Beverage Group Ltd
Amendment No. 8 to the Registration Statement on Form F-1
File No. 333-266965
Filed November 15, 2022
Dear Ms. Haywood and Mr. Ewing:
Innovation Beverage Group Ltd
(the “Company” or “IBG”) previously submitted Amendment No. 7 to the Company’s Registration
Statement on Form F-1 (the “Registration Statement”) pursuant to Title I, Section 106 under the Jumpstart Our Business
Startups Act with the Securities and Exchange Commission (the “Commission”) on October 25, 2022. Amendment No. 8 responds
to the comment letter received on November 4, 2022 from the staff of the Commission (the “Staff”). For ease of review,
we have set forth below the comment of your letter followed by the Company’s response thereto.
Risk Factors, page 16
1. We note recent instances of extreme stock price run-ups followed by rapid
price declines and stock price volatility seemingly unrelated to company performance following a number of recent initial public offerings,
particularly among companies with relatively smaller public floats. Revise to include a separate risk factor addressing the potential
for rapid and substantial price volatility and any known factors particular to your offering that may add to this risk and discuss the
risks to investors when investing in stock where the price is changing rapidly. Clearly state that such volatility, including any stock-run
up, may be unrelated to your actual or expected operating performance and financial condition or prospects, making it difficult for prospective
investors to assess the rapidly changing value of your stock.
Response: The Company acknowledges the Staff’s
comment and has made the requested revision on page 32. Please see the risk factor titled, “The market price of our ordinary shares
and warrants may be highly volatile, and you could lose all or part of your investment.”
Should you have any questions
regarding the foregoing, please do not hesitate to contact the Company’s counsel, Darrin Ocasio, of Sichenzia Ross Ference LLP at
(212) 930-9700.
Sincerely,
Dean Huge
Chief Executive Officer
cc: Darrin Ocasio