SEC Comment Letter 0000000000-25-001029 to Orbit Innovations Group Inc. (CIK 0002041999)
Orbit Innovations Group Inc. (CIK 0002041999)
Date: Jan. 31, 2025 · CIK: 0002041999 · Accession: 0000000000-25-001029
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File numbers found in text: 333-283342
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January 31, 2025
Svetlana Belychova
Chief Executive Officer
Orbit Innovations Group Inc.
Vrabci 9
Prague, Czech Republic 18200
Re:Orbit Innovations Group Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed January 6, 2025
File No. 333-283342
Dear Svetlana Belychova:
We have reviewed your amended registration statement and have the following
comment(s).
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 December 17,
2024 letter.
Amendment No. 1 to Registration Statement on Form S-1 Filed January 6, 2025
Description of Business
General Information, page 22
1.We note your revised disclosure in response to prior comment 8. Please provide
additional detail regarding the anticipated timeline of operations. We note in your
Plan of Operations that you expect certain projects will take certain estimated periods,
for example, that Design Software is anticipated to take one to two months. To give
additional information to investors, please elaborate on your anticipated timeline to
provide a potential start date for the disclosed stages of development.
January 31, 2025
Page 2
Item 16. Exhibits, page 38
2.Please revise your Exhibit Index to include the consent associated with your counsel's
legal opinion, filed as Exhibit 5.1. Refer to Item 601(b)(23)(i) of Regulation S-K.
Please contact Patrick Kuhn at 202-551-3308 or Adam Phippen at 202-551-3336 if
you have questions regarding comments on the financial statements and related
matters. Please contact Alyssa Wall at 202-551-8106 or Cara Wirth at 202-551-7127 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services