Correspondence 0001376474-24-000334 from ZenaTech, Inc. (ZENA)
ZenaTech, Inc.
Date: July 25, 2024 · CIK: 0001997403 · Accession: 0001376474-24-000334
AI Filing Summary & Sentiment
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: Re: ZenaTech, Inc. - Form F-1 (Amendment No. 7)
We are legal counsel in Canada for ZenaTech, Inc. (“the Company”). On behalf of the Company, we are writing to notify the United States Securities and Exchange Commission (the “SEC”) that the Company has filed an amended Registration Statement on Form F-1 (Amendment No. 7) (the “Registration Statement”) in connection with a proposed listing of its common stock on The Nasdaq Capital Market to reflect the following:
1.On July 1, 2024, a 1 for 6 reverse stock split of its common shares was effected by the Company. All share and per share data presented in the Registration Statement has been adjusted to give effect to the reverse stock split and footnotes 21 and 22 have been added to the financial statements in that regard.
2.On July 15, 2024, the Company issued 291,829 common shares at a price of $10.28 for gross proceeds of approximately $3,000,000.
3.The Company has made minor amendments to the Registration Statement to better present or clarify the disclosure.
The Company is proposing to make an acceleration request for effectiveness of the Registration Statement once these amendments are cleared by the SEC.
We trust the foregoing will be satisfactory. However, 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/13167945.1
Page 2
Yours truly,
Boughton Law Corporation
/s/ Karim Lalani
Karim Lalani
Counsel
cc: Shaun Passley PhD.
ZenaTech, Inc.
AC/13167945.1
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CORRESP 1 filename1.htm SEC Correspondence July 25, 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: Re: ZenaTech, Inc. - Form F-1 (Amendment No. 7) We are legal counsel in Canada for ZenaTech, Inc. (“the Company”). On behalf of the Company, we are writing to notify the United States Securities and Exchange Commission (the “SEC”) that the Company has filed an amended Registration Statement on Form F-1 (Amendment No. 7) (the “Registration Statement”) in connection with a proposed listing of its common stock on The Nasdaq Capital Market to reflect the following: 1.On July 1, 2024, a 1 for 6 reverse stock split of its common shares was effected by the Company. All share and per share data presented in the Registration Statement has been adjusted to give effect to the reverse stock split and footnotes 21 and 22 have been added to the financial statements in that regard. 2.On July 15, 2024, the Company issued 291,829 common shares at a price of $10.28 for gross proceeds of approximately $3,000,000. 3.The Company has made minor amendments to the Registration Statement to better present or clarify the disclosure. The Company is proposing to make an acceleration request for effectiveness of the Registration Statement once these amendments are cleared by the SEC. We trust the foregoing will be satisfactory. However, 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/13167945.1 Page 2 Yours truly, Boughton Law Corporation /s/ Karim Lalani Karim Lalani Counsel cc: Shaun Passley PhD. ZenaTech, Inc. AC/13167945.1