SEC Comment Letter 0000000000-23-006328 to aShareX Fine Art, LLC (CIK 0001964674)
aShareX Fine Art, LLC (CIK 0001964674)
Date: June 13, 2023 · CIK: 0001964674 · Accession: 0000000000-23-006328
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo June 13, 2023 Alan Snyder Chief Executive Officer aShareX Fine Art, LLC 10990 Wilshire Blvd., Suite 1150 Los Angeles, California 90024 Re:aShareX Fine Art, LLC Draft Offering Statement on Form 1-A Response dated May 25, 2023 CIK No. 0001964674 Dear Alan Snyder: We have reviewed your May 25, 2023 response to our comment letter 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 amending your offering statement and providing the requested information. 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 offering statement and the information you provide in response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our May 22, 2023 letter. Response dated May 25, 2023 General 1.We note your response to comment 1 and disagree with your analysis. Rule 255(a) prohibits the solicitation of any commitment, binding or otherwise, from any person until qualification of an offering statement. It appears that, via the bidding process, you are soliciting pre-qualification commitments that are prohibited by Rule 255(a). In this regard, we note that revocability of the pre-qualification bids doesn't make these bids permissible solicitation of interests. Please revise the structure of the bid process so that you are in compliance with Regulation A.
FirstName LastNameAlan Snyder Comapany NameaShareX Fine Art, LLC June 13, 2023 Page 2 FirstName LastName Alan Snyder aShareX Fine Art, LLC June 13, 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
June 13, 2023
Alan Snyder
Chief Executive Officer
aShareX Fine Art, LLC
10990 Wilshire Blvd., Suite 1150
Los Angeles, California 90024
Re:aShareX Fine Art, LLC
Draft Offering Statement on Form 1-A
Response dated May 25, 2023
CIK No. 0001964674
Dear Alan Snyder:
We have reviewed your May 25, 2023 response to our comment letter 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 amending your offering statement and providing the
requested information. 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 offering statement and the information you
provide in response to this comment, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our May 22, 2023 letter.
Response dated May 25, 2023
General
1.We note your response to comment 1 and disagree with your analysis. Rule 255(a)
prohibits the solicitation of any commitment, binding or otherwise, from any person until
qualification of an offering statement. It appears that, via the bidding process, you are
soliciting pre-qualification commitments that are prohibited by Rule 255(a). In this
regard, we note that revocability of the pre-qualification bids doesn't make these bids
permissible solicitation of interests. Please revise the structure of the bid process so that
you are in compliance with Regulation A.
FirstName LastNameAlan Snyder
Comapany NameaShareX Fine Art, LLC
June 13, 2023 Page 2
FirstName LastName
Alan Snyder
aShareX Fine Art, LLC
June 13, 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