SEC Comment Letter 0000000000-25-004820 to Ex-Im America Ltd (CIK 0002043188)
Ex-Im America Ltd (CIK 0002043188)
Date: May 7, 2025 · CIK: 0002043188 · Accession: 0000000000-25-004820
AI Filing Summary & Sentiment
File numbers found in text: 024-12542
Letter
May 7, 2025 William Westbrook Chief Executive Officer Ex-Im America Ltd. 4040 Broadway San Antonio, TX 78209 Re:Ex-Im America Ltd. Amendment No. 3 to Offering Statement on Form 1-A Filed April 28, 2025 File No. 024-12542 Dear William Westbrook: We have reviewed your amended offering statement and have the following comments. Please respond to this letter by amending your offering 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 offering 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 April 14, 2025 letter. Amendment No. 3 to the Offering Statement on Form 1-A Signatures, page 26 1.We note the revisions made in response to prior 4 and we re-issue this comment in part. In the latest amendment to the offering statement, Luis Vega signed the offering statement on behalf of the issuer. Luis Vega should also sign the offering statement in his individual capacity. In this regard, his signature should appear a second time in the section where the other three executive officers' signatures appear. General We note the revisions made in response to prior comment 6. Please revise Item 4 of Part I of Form 1-A to select the "Yes" checkbox in response to the question asking whether you intend to offer the securities on a delayed or continuous basis pursuant to 2.
May 7, 2025 Page 2 Rule 251(d)(3). In this regard, we note that the offering may last up to one year, which would appear to make it a continuous offering. Alternatively, tell us why you believe this is not a delayed or continuous offering pursuant to Rule 251(d)(3). Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage at 202- 551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact Mitchell Austin at 202-551-3574 or Jan Woo at 202-551-3453 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc:Richard W. Jones
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May 7, 2025
William Westbrook
Chief Executive Officer
Ex-Im America Ltd.
4040 Broadway
San Antonio, TX 78209
Re:Ex-Im America Ltd.
Amendment No. 3 to Offering Statement on Form 1-A
Filed April 28, 2025
File No. 024-12542
Dear William Westbrook:
We have reviewed your amended offering statement and have the following
comments.
Please respond to this letter by amending your offering 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 offering 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 April 14, 2025 letter.
Amendment No. 3 to the Offering Statement on Form 1-A
Signatures, page 26
1.We note the revisions made in response to prior 4 and we re-issue this comment in
part. In the latest amendment to the offering statement, Luis Vega signed the offering
statement on behalf of the issuer. Luis Vega should also sign the offering statement in
his individual capacity. In this regard, his signature should appear a second time in the
section where the other three executive officers' signatures appear.
General
We note the revisions made in response to prior comment 6. Please revise Item 4 of
Part I of Form 1-A to select the "Yes" checkbox in response to the question asking
whether you intend to offer the securities on a delayed or continuous basis pursuant to 2.
May 7, 2025
Page 2
Rule 251(d)(3). In this regard, we note that the offering may last up to one year, which
would appear to make it a continuous offering. Alternatively, tell us why you believe
this is not a delayed or continuous offering pursuant to Rule 251(d)(3).
Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage at 202-
551-3361 if you have questions regarding comments on the financial statements and related
matters. Please contact Mitchell Austin at 202-551-3574 or Jan Woo at 202-551-3453 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Richard W. Jones