Correspondence 0001376474-24-000279 from ZenaTech, Inc. (ZENA)
ZenaTech, Inc.
Date: June 21, 2024 · CIK: 0001997403 · Accession: 0001376474-24-000279
AI Filing Summary & Sentiment
Referenced dates: June 20, 2024
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Attention:Aliya Ishmukhamedova Jan Woo Amanda Kim Stephen Krikorian
Dear Sirs and Mesdames:
Re: ZenaTech, Inc. – Form F-1 – SEC Comment Letter Dated June 20, 2024
We are legal counsel in Canada for ZenaTech, Inc. (“the Company”). On behalf of the Company, we are writing to respond to the comments raised in the letter (the “Sixth Comment Letter”) to the Company dated June 20, 2024 from the United States Securities and Exchange Commission (the “SEC”) with respect to the Registration Statement on Form F-1 (Amendment No. 5) (the “Registration Statement”) filed by the Company with the SEC on June 7, 2024 in connection with a proposed listing of its common stock on The Nasdaq Capital Market. The responses below are from the Company and correspond to the captions and numbers set forth in the Sixth Comment Letter (which are reproduced below in bold). Capitalized terms used in this response letter but not otherwise defined have the meanings assigned to them in the First Comment Letter.
Amendment No. 5 to Registration Statement on Form F-1
Account Name Changes and Reclassifications, 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.
Response: The Company has amended the Registration Statement as requested.
We trust the foregoing answers are responsive to your comments. Please do not hesitate to contact me by telephone at (604) 512-7910 or via email at klalani@boughtonlaw.com with any questions or comments regarding this correspondence.
AC/13110072.1
Page 2
Yours truly,
Boughton Law Corporation
/s/ Karim Lalani
Karim Lalani
Counsel
cc: Shaun Passley PhD.
ZenaTech, Inc.
AC/13110072.1
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CORRESP 1 filename1.htm June 21, 2024 File #: 97353.1 Direct: 604 647 4124 Email: klalani@boughtonlaw.com VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, DC 20549 Attention:Aliya Ishmukhamedova Jan Woo Amanda Kim Stephen Krikorian Dear Sirs and Mesdames: Re: ZenaTech, Inc. – Form F-1 – SEC Comment Letter Dated June 20, 2024 We are legal counsel in Canada for ZenaTech, Inc. (“the Company”). On behalf of the Company, we are writing to respond to the comments raised in the letter (the “Sixth Comment Letter”) to the Company dated June 20, 2024 from the United States Securities and Exchange Commission (the “SEC”) with respect to the Registration Statement on Form F-1 (Amendment No. 5) (the “Registration Statement”) filed by the Company with the SEC on June 7, 2024 in connection with a proposed listing of its common stock on The Nasdaq Capital Market. The responses below are from the Company and correspond to the captions and numbers set forth in the Sixth Comment Letter (which are reproduced below in bold). Capitalized terms used in this response letter but not otherwise defined have the meanings assigned to them in the First Comment Letter. Amendment No. 5 to Registration Statement on Form F-1 Account Name Changes and Reclassifications, 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. Response: The Company has amended the Registration Statement as requested. We trust the foregoing answers are responsive to your comments. Please do not hesitate to contact me by telephone at (604) 512-7910 or via email at klalani@boughtonlaw.com with any questions or comments regarding this correspondence. AC/13110072.1 Page 2 Yours truly, Boughton Law Corporation /s/ Karim Lalani Karim Lalani Counsel cc: Shaun Passley PhD. ZenaTech, Inc. AC/13110072.1