SEC Comment Letter 0000000000-23-012171 to IMA Tech (IMAA)
IMA Tech
Date: Nov. 7, 2023 · CIK: 0001980295 · Accession: 0000000000-23-012171
AI Filing Summary & Sentiment
File numbers found in text: 333-273283
Letter
United States securities and exchange commission logo November 7, 2023 Liliia Havrykh Chief Executive Officer IMA Tech Inc. 34 N Franklin Ave 687 Pinedale, WY 82941 Re:IMA Tech Inc. Amendment No. 3 to Registration Statement on Form S-1 Filed October 27, 2023 File No. 333-273283 Dear Liliia Havrykh: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration 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 registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our October 18, 2023 letter. Form S-1/A filed October 27, 2023 Our Company, page 9 1.We note your response to prior comment 1. Please provide a more complete discussion regarding the development of your codebase, including whether you entered into any material agreements with external developers and the terms of those agreements, quantify the costs for the periods presented, and file the agreements as exhibits, or tell us why it is not required. In addition, to the extent true, clarify that the company has limited control over the open-source software used and provide corresponding risk factor disclosure as appropriate.
FirstName LastNameLiliia Havrykh Comapany NameIMA Tech Inc. November 7, 2023 Page 2 FirstName LastName Liliia Havrykh IMA Tech Inc. November 7, 2023 Page 2 Please contact Joyce Sweeney at 202-551-3449 or Christine Dietz at 202-551-3408 if you have questions regarding comments on the financial statements and related matters. Please contact Marion Graham at 202-551-6521 or Matthew Derby at 202-551-3334 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Robert Zepfel
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United States securities and exchange commission logo
November 7, 2023
Liliia Havrykh
Chief Executive Officer
IMA Tech Inc.
34 N Franklin Ave 687
Pinedale, WY 82941
Re:IMA Tech Inc.
Amendment No. 3 to Registration Statement on Form S-1
Filed October 27, 2023
File No. 333-273283
Dear Liliia Havrykh:
We have reviewed your amended registration statement and have the following comment.
Please respond to this letter by amending your registration 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 registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our October 18, 2023 letter.
Form S-1/A filed October 27, 2023
Our Company, page 9
1.We note your response to prior comment 1. Please provide a more complete discussion
regarding the development of your codebase, including whether you entered into any
material agreements with external developers and the terms of those agreements, quantify
the costs for the periods presented, and file the agreements as exhibits, or tell us why it is
not required. In addition, to the extent true, clarify that the company has limited control
over the open-source software used and provide corresponding risk factor disclosure as
appropriate.
FirstName LastNameLiliia Havrykh
Comapany NameIMA Tech Inc.
November 7, 2023 Page 2
FirstName LastName
Liliia Havrykh
IMA Tech Inc.
November 7, 2023
Page 2
Please contact Joyce Sweeney at 202-551-3449 or Christine Dietz at 202-551-3408 if you
have questions regarding comments on the financial statements and related matters. Please
contact Marion Graham at 202-551-6521 or Matthew Derby at 202-551-3334 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Robert Zepfel