Correspondence 0001096906-25-000261 from Block40X, Inc. (CIK 0002055672)
Block40X, Inc. (CIK 0002055672)
Date: March 17, 2025 · CIK: 0002055672 · Accession: 0001096906-25-000261
AI Filing Summary & Sentiment
File numbers found in text: 024-12577
Referenced dates: March 14, 2025
Letter
Division of Corporation Finance Office of Crypto Assets Securities and Exchange Commission 100 F. Street, NE Washington, DC 20549 Re: Block40X, Inc., Amendment No. 1 to Offering Statement on Form 1-A Filed March 5, 2025 File No. 024-12577
Dear Mr. Gessert:
I have reviewed the staff’s comment letter dated March 14, 2025. Amendment No. 2 to the offering statement is being filed in response. Your comments are reproduced below followed by our response in italics.
Offering Circular Summary
The Current Offering - Securities offered, page 6
1. We note the revisions you made in response to prior comment 1. Please expand your disclosure here to disclose the 15% discount for purchasers of 4 million or more shares of your securities and summarize how the bonus shares will be allocated, or the offering price discount will be applied.
Complied by adding a new footnote to the table on page 6.
Risk Factors
Risk Factors Related to Hardware Modifications or Adaptations for Leasing Servers to AI Companies, page 9
2.Please remove reference to the iShares Bitcoin Trust Form S-1 and revise your discussions to address risks attendant to your proposed business operations.
Complied on page 9.
The Company's Business
Cybersecurity, page 39
3. We note your response to prior comment 19. Please revise your disclosure under this heading to clarify that you have not yet entered into a custody agreement. Please make similar revisions to the first risk factor on page 18.
Complied on pages 18 and 39.
Very truly yours,
/s/ B Joshua Hoskins
Show Raw Text
CORRESP 1 filename1.htm BLOCK40X, INC. 1033 West 400 South American Fork, Utah 84003 (702) 485-0110 March 17, 2025 David Gessert Division of Corporation Finance Office of Crypto Assets Securities and Exchange Commission 100 F. Street, NE Washington, DC 20549 Re: Block40X, Inc., Amendment No. 1 to Offering Statement on Form 1-A Filed March 5, 2025 File No. 024-12577 Dear Mr. Gessert: I have reviewed the staff’s comment letter dated March 14, 2025. Amendment No. 2 to the offering statement is being filed in response. Your comments are reproduced below followed by our response in italics. Offering Circular Summary The Current Offering - Securities offered, page 6 1. We note the revisions you made in response to prior comment 1. Please expand your disclosure here to disclose the 15% discount for purchasers of 4 million or more shares of your securities and summarize how the bonus shares will be allocated, or the offering price discount will be applied. Complied by adding a new footnote to the table on page 6. Risk Factors Risk Factors Related to Hardware Modifications or Adaptations for Leasing Servers to AI Companies, page 9 2.Please remove reference to the iShares Bitcoin Trust Form S-1 and revise your discussions to address risks attendant to your proposed business operations. Complied on page 9. The Company's Business Cybersecurity, page 39 3. We note your response to prior comment 19. Please revise your disclosure under this heading to clarify that you have not yet entered into a custody agreement. Please make similar revisions to the first risk factor on page 18. Complied on pages 18 and 39. Very truly yours, /s/ B Joshua Hoskins B. Joshua Hoskins President