Correspondence 0001477932-25-003670 from Ex-Im America Ltd (CIK 0002043188)
Ex-Im America Ltd (CIK 0002043188)
Date: May 14, 2025 · CIK: 0002043188 · Accession: 0001477932-25-003670
AI Filing Summary & Sentiment
Letter
Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Attn: Mr. Mitchell Austin
Dear Mr. Austin and Members of the Division of Corporation Finance:
Subject: Request for Qualification of Form 1-A Offering Statement for Ex-Im America Ltd.
Ex-Im America Ltd., a Wyoming corporation with its principal office at 20551 N. Pima Rd., Suite 200, Scottsdale, AZ 85255-7206, respectfully requests qualification of its Regulation A Offering Statement on Form 1-A, as amended (Amendment No. 3 filed April 1, 2025), pursuant to Section 3(b) of the Securities Act of 1933, as amended. The offering consists of up to 10,000,000 shares of common stock at $1.50 per share, with a maximum offering amount of $15,000,000, under a Tier 1 exemption.
Per your recent communication, we confirm that all comments provided by the SEC have been addressed in Amendment No. 3 to the Form 1-A, filed April 1, 2025. The Offering Circular (dated March 5, 2025), financial statements, and exhibits, including the legal opinion from Jones & Haley, P.C. (Exhibit 17.12, dated March 26, 2025), are complete and in compliance with SEC requirements. Our legal counsel, located at 750 Hammond Drive, Building 12, Suite 100, Atlanta, GA 30328, has reviewed the filing and affirms the validity of the shares offered.
We respectfully request that the Commission qualify the Offering Statement effective on or about May 27, 2025, or as soon thereafter as practicable, to enable the commencement of the offering. We are prepared to provide any additional information or documentation required to facilitate this process.
Please direct any questions or correspondence to Luis J. Vega, President and Chief Financial Officer, at (956) 877-5121 or info@simultrayd.com, with a copy to our counsel, Rick Jones at Jones & Haley, P.C. We appreciate your guidance and look forward to the qualification of our offering.
Sincerely,
/S/ William Westbrook
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CORRESP 1 filename1.htm exim_corresp.htm Ex-Im America Ltd. 20551 N Pima Rd Suite 200 Scottsdale, AZ 85255 May 14, 2025 Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Attn: Mr. Mitchell Austin Dear Mr. Austin and Members of the Division of Corporation Finance: Subject: Request for Qualification of Form 1-A Offering Statement for Ex-Im America Ltd. Ex-Im America Ltd., a Wyoming corporation with its principal office at 20551 N. Pima Rd., Suite 200, Scottsdale, AZ 85255-7206, respectfully requests qualification of its Regulation A Offering Statement on Form 1-A, as amended (Amendment No. 3 filed April 1, 2025), pursuant to Section 3(b) of the Securities Act of 1933, as amended. The offering consists of up to 10,000,000 shares of common stock at $1.50 per share, with a maximum offering amount of $15,000,000, under a Tier 1 exemption. Per your recent communication, we confirm that all comments provided by the SEC have been addressed in Amendment No. 3 to the Form 1-A, filed April 1, 2025. The Offering Circular (dated March 5, 2025), financial statements, and exhibits, including the legal opinion from Jones & Haley, P.C. (Exhibit 17.12, dated March 26, 2025), are complete and in compliance with SEC requirements. Our legal counsel, located at 750 Hammond Drive, Building 12, Suite 100, Atlanta, GA 30328, has reviewed the filing and affirms the validity of the shares offered. We respectfully request that the Commission qualify the Offering Statement effective on or about May 27, 2025, or as soon thereafter as practicable, to enable the commencement of the offering. We are prepared to provide any additional information or documentation required to facilitate this process. Please direct any questions or correspondence to Luis J. Vega, President and Chief Financial Officer, at (956) 877-5121 or info@simultrayd.com, with a copy to our counsel, Rick Jones at Jones & Haley, P.C. We appreciate your guidance and look forward to the qualification of our offering. Sincerely, /S/ William Westbrook William Westbrook Chairman and Chief Executive Officer Ex-Im America Ltd. /S/ Luis J. Vega Luis J. Vega President, Treasurer, and Chief Financial Officer Ex-Im America Ltd.