SEC Comment Letter 0000000000-23-003525 to aShareX Fine Art, LLC (CIK 0001964674)
aShareX Fine Art, LLC (CIK 0001964674)
Date: April 10, 2023 · CIK: 0001964674 · Accession: 0000000000-23-003525
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo April 10, 2023 Alan Snyder Chief Executive Officer aShareX Fine Art, LLC 10990 Wilshire Blvd., Suite 1150 Los Angeles, California 90024 Re:aShareX Fine Art, LLC Amendment No. 1 to Draft Offering Statement on Form 1-A Submitted March 17, 2023 CIK No. 0001964674 Dear Alan Snyder: We have reviewed your amended draft offering statement and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by providing the requested information and either submitting an amended draft offering statement or publicly filing your offering statement on EDGAR. If you do not believe our comment applies 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 draft offering statement or filed offering statement and the information you provide in response to this comment, we may have additional comments. Amendment No. 1 to Draft Offering Statement on Form 1-A The Offering, page 12 1.We note your response to comment 1 and reissue. We note your disclosure that the company anticipates that the auction for each series will be held within 60 days of the offering for the series being qualified. We also note that this appears to be a delayed offering not permitted by Rule 251(d)(3)(i) of Regulation A. Please revise to remove the auction pricing feature. In this regard, we note that you will not be ready and willing to sell the securities at all times within two days of qualification. Within two days of qualification, the company will not have a final price and thus will not be ready and willing to sell the securities.
FirstName LastNameAlan Snyder Comapany NameaShareX Fine Art, LLC April 10, 2023 Page 2 FirstName LastName Alan Snyder aShareX Fine Art, LLC April 10, 2023 Page 2 Please contact Alyssa Wall at 202-551-8106 or Donald Field at 202-551-3680 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Alison Pear
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United States securities and exchange commission logo
April 10, 2023
Alan Snyder
Chief Executive Officer
aShareX Fine Art, LLC
10990 Wilshire Blvd., Suite 1150
Los Angeles, California 90024
Re:aShareX Fine Art, LLC
Amendment No. 1 to Draft Offering Statement on Form 1-A
Submitted March 17, 2023
CIK No. 0001964674
Dear Alan Snyder:
We have reviewed your amended draft offering statement and have the following
comment. In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter by providing the requested information and either submitting
an amended draft offering statement or publicly filing your offering statement on EDGAR. If
you do not believe our comment applies 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 draft offering statement or filed offering statement and the information you provide in
response to this comment, we may have additional comments.
Amendment No. 1 to Draft Offering Statement on Form 1-A
The Offering, page 12
1.We note your response to comment 1 and reissue. We note your disclosure that the
company anticipates that the auction for each series will be held within 60 days of the
offering for the series being qualified. We also note that this appears to be a delayed
offering not permitted by Rule 251(d)(3)(i) of Regulation A. Please revise to remove the
auction pricing feature. In this regard, we note that you will not be ready and willing to
sell the securities at all times within two days of qualification. Within two days of
qualification, the company will not have a final price and thus will not be ready and
willing to sell the securities.
FirstName LastNameAlan Snyder
Comapany NameaShareX Fine Art, LLC
April 10, 2023 Page 2
FirstName LastName
Alan Snyder
aShareX Fine Art, LLC
April 10, 2023
Page 2
Please contact Alyssa Wall at 202-551-8106 or Donald Field at 202-551-3680 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Alison Pear