SEC Comment Letter 0000000000-24-007037 to ZenaTech, Inc. (ZENA)
ZenaTech, Inc.
Date: June 20, 2024 · CIK: 0001997403 · Accession: 0000000000-24-007037
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File numbers found in text: 333-276838
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United States securities and exchange commission logo
June 20, 2024
Shaun Passley
Chief Executive Officer
ZenaTech, Inc.
69 Yonge St. Suite 1404
Toronto, Ontario Canada M5E 1K3
Re:ZenaTech, Inc.
Amendment No. 5 to Registration Statement on Form F-1
Filed June 7, 2024
File No. 333-276838
Dear Shaun Passley:
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 a 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 June 6, 2024 letter.
Amendment No. 5 to Registration Statement on Form F-1
Account Name Changes and Reclassification, page 180
1.We have reviewed your response to prior comment 2. Additionally, you disclose on pages
147 and 180 that you changed the account name from "Salaries and benefits" to "Wages
and benefits." However, you made this change in certain places of the filing but not in
others. Please revise or advise.
FirstName LastNameShaun Passley
Comapany NameZenaTech, Inc.
June 20, 2024 Page 2
FirstName LastName
Shaun Passley
ZenaTech, Inc.
June 20, 2024
Page 2
Please contact Amanda Kim at 202-551-3241 or Stephen Krikorian at 202-551-3488 if
you have questions regarding comments on the financial statements and related matters. Please
contact Aliya Ishmukhamedova at 202-551-7519 or Matthew Derby at 202-551-3334 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Karim Lalani