Correspondence 0001493152-24-030279 from LELANTOS HOLDINGS INC. (LNTO) (CIK 0002006925) (LNTO)
LELANTOS HOLDINGS INC. (LNTO) (CIK 0002006925)
Date: Aug. 5, 2024 · CIK: 0002006925 · Accession: 0001493152-24-030279
AI Filing Summary & Sentiment
File numbers found in text: 024-12414
Letter
Re: Lelantos Holdings, Inc.
August 5, 2024
Securities and Exchange Commission
Division of Corporate Finance
Office of Energy and Transportation
Washington, D.C.
Amendment No. 4 to Offering Statement on Form 1-A
Filed July 15, 2024
File No. 024-12414
Dear, Anuja Majmudar:
Pursuant to the commentary letter provided on July 29, 2024, I have outlined responses to each of the items listed in the commentary letter. Corresponding amendments have been made to the body of the Offering Statement as well.
General
1. Please tell us whether the members of Lelantos Holdings hold interests in Eco Management directly as individuals, or do they hold their interest through Lelantos Holdings (i.e., does Joshua Weaver own 16% of Eco Management economic rights and 32% of its voting rights as an individual, or does Lelantos Holdings own 50% of Eco Management, and Joshua Weaver holds his interests in Eco Management through his interest in Lelantos Holdings?).
Response
To clarify, the members of Lelantos Holdings hold an interest in Eco Management through their position on the Lelantos Holdings board. The board seats hold the voting rights and interest in the subsidiary. If the individuals (Joshua Weaver, Nathan Puente, and Sean Land) are removed from the board, the interest and voting rights in Eco Management Systems will remain in the parent company. Please see the attached org chart with the requested revisions that further note this. This clarification has also been added to the body of the offering circular under the description of Eco Management Systems.
2. We note the organization chart shows the officers of the entities, but not distribution of ownership interests. Please provide an organization chart that shows the distribution of ownership interests of Eco Management Systems and Lelantos Holdings.
Response
The organization chart (attached) has been updated to reflect the ownership interests of Eco Management and Lelantos Holdings.
Truly
Yours
Nathan
Puente
Show Raw Text
CORRESP 1 filename1.htm August 5, 2024 Securities and Exchange Commission Division of Corporate Finance Office of Energy and Transportation Washington, D.C. Re: Lelantos Holdings, Inc. Amendment No. 4 to Offering Statement on Form 1-A Filed July 15, 2024 File No. 024-12414 Dear, Anuja Majmudar: Pursuant to the commentary letter provided on July 29, 2024, I have outlined responses to each of the items listed in the commentary letter. Corresponding amendments have been made to the body of the Offering Statement as well. General 1. Please tell us whether the members of Lelantos Holdings hold interests in Eco Management directly as individuals, or do they hold their interest through Lelantos Holdings (i.e., does Joshua Weaver own 16% of Eco Management economic rights and 32% of its voting rights as an individual, or does Lelantos Holdings own 50% of Eco Management, and Joshua Weaver holds his interests in Eco Management through his interest in Lelantos Holdings?). Response To clarify, the members of Lelantos Holdings hold an interest in Eco Management through their position on the Lelantos Holdings board. The board seats hold the voting rights and interest in the subsidiary. If the individuals (Joshua Weaver, Nathan Puente, and Sean Land) are removed from the board, the interest and voting rights in Eco Management Systems will remain in the parent company. Please see the attached org chart with the requested revisions that further note this. This clarification has also been added to the body of the offering circular under the description of Eco Management Systems. 2. We note the organization chart shows the officers of the entities, but not distribution of ownership interests. Please provide an organization chart that shows the distribution of ownership interests of Eco Management Systems and Lelantos Holdings. Response The organization chart (attached) has been updated to reflect the ownership interests of Eco Management and Lelantos Holdings. Truly Yours Nathan Puente CEO Lelantos Holdings Nathan@Lelantos.Group 520-256-2248