SecProbe.io

Filing text and metadata
Intelligence Terminal Search Topics Monthly Activity About

SEC Comment Letter 0000000000-23-010197 to GlobalTech Corp (GLTK) (CIK 0001938338) (GLTK)

GlobalTech Corp (GLTK) (CIK 0001938338)
Date: Sept. 14, 2023 · CIK: 0001938338 · Accession: 0000000000-23-010197

AI Filing Summary & Sentiment

File numbers found in text: 000-56482

Date
September 14, 2023
Author
Office of Technology
Form
UPLOAD
Company
GlobalTech Corp (GLTK) (CIK 0001938338)

Letter

United States securities and exchange commission logo September 14, 2023 Dana Green Chief Executive Officer GlobalTech Corp 3550 Barron Way, Suite 13a Reno, NV 89511 Re:GlobalTech Corp Amendment No. 4 to Form 10-K for the Fiscal Year Ended December 31, 2022 Amendment No. 3 to Form 10-Q for the Quarterly Period Ended March 31, File No. 000-56482 Dear Dana Green: We have reviewed your filing 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 these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Amendment No. 4 to Form 10-K for the fiscal year ended December 31, 2022 Notes to Consolidated Financial Statements Note 2. Basis of Preparation of Consolidated Financial Statements Restatement of Prior Balances, page F-13 1.We note the revisions in response to prior comment 1. Please revise the amounts included in the column labeled as “as presented” to agree to the December 31, 2021 balances as originally reported in the Form 10-K for the fiscal year ended December 31, 2022, filed on March 31, 2023. Alternatively, if the financial statements in the subsequent amendments are being restated, please clarify your disclosure.

FirstName LastNameDana Green Comapany NameGlobalTech Corp September 14, 2023 Page 2 FirstName LastName Dana Green GlobalTech Corp September 14, 2023 Page 2 2.Please explain how you computed the adjustment amount related to restatement (c). That is, we note that you reversed a bargain purchase gain of $7.3M previously recognized on the acquisition of Ferret and recognized a bargain purchase of $407K on the reverse merger. As such, it appears the restatement should result in an adjustment to other income of $6.9M. Please explain or revise. Amendment No. 3 to Form 10-Q for the quarterly period year ended March 31, 2023 Notes to Consolidated Financial Statements Note 2. Basis of Preparation of Consolidated Financial Statements Restatement of Prior Balances, page 14 3.Please revise to provide the disclosures required by ASC 250-10-50-7 for each of the periods presented in the filing. In this regard, we note that you have disclosed the impact of the restatements on the balance sheet as of December 31, 2021, the statements of operations for the year ended December 31, 2021 and 2022, and the statement of cash flows for the year ended December 31, 2021. Please also make applicable changes to the disclosures in Amendment No. 1 to Form 10-Q for the quarterly period ended June 30, 2023. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Melissa Walsh, Senior Staff Accountant, at (202) 551-3224 or Stephen Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding comments on the financial statements and related matters. Please contact Kyle Wiley, Staff Attorney, at (202) 344-5791 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Sean Neahusan

Show Raw Text
United States securities and exchange commission logo
September 14, 2023
Dana Green
Chief Executive Officer
GlobalTech Corp
3550 Barron Way, Suite 13a
Reno, NV 89511
Re:GlobalTech Corp
Amendment No. 4 to Form 10-K for the Fiscal Year Ended December 31, 2022
Amendment No. 3 to Form 10-Q for the Quarterly Period Ended March 31,
2023
File No. 000-56482
Dear Dana Green:
            We have reviewed your filing 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Amendment No. 4 to Form 10-K for the fiscal year ended December 31, 2022
Notes to Consolidated Financial Statements
Note 2. Basis of Preparation of Consolidated Financial Statements
Restatement of Prior Balances, page F-13
1.We note the revisions in response to prior comment 1.  Please revise the amounts included
in the column labeled as “as presented” to agree to the December 31, 2021 balances as
originally reported in the Form 10-K for the fiscal year ended December 31, 2022, filed on
March 31, 2023.  Alternatively, if the financial statements in the subsequent amendments
are being restated, please clarify your disclosure.

 FirstName LastNameDana Green
 Comapany NameGlobalTech Corp
 September 14, 2023 Page 2
 FirstName LastName
Dana Green
GlobalTech Corp
September 14, 2023
Page 2
2.Please explain how you computed the adjustment amount related to restatement (c).  That
is, we note that you reversed a bargain purchase gain of $7.3M previously recognized on
the acquisition of Ferret and recognized a bargain purchase of $407K on the reverse
merger.  As such, it appears the restatement should result in an adjustment to other income
of $6.9M.  Please explain or revise.
Amendment No. 3 to Form 10-Q for the quarterly period year ended March 31, 2023
Notes to Consolidated Financial Statements
Note 2. Basis of Preparation of Consolidated Financial Statements
Restatement of Prior Balances, page 14
3.Please revise to provide the disclosures required by ASC 250-10-50-7 for each of the
periods presented in the filing.  In this regard, we note that you have disclosed the impact
of the restatements on the balance sheet as of December 31, 2021, the statements of
operations for the year ended December 31, 2021 and 2022, and the statement of cash
flows for the year ended December 31, 2021.  Please also make applicable changes to the
disclosures in Amendment No. 1 to Form 10-Q for the quarterly period ended June 30,
2023.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Melissa Walsh, Senior Staff Accountant, at (202) 551-3224 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the financial statements and related matters.  Please contact Kyle Wiley, Staff
Attorney, at (202) 344-5791 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Sean Neahusan