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AIBOTICS, INC.
CIK: 0001763329  ·  File(s): 024-12597  ·  Started: 2025-04-03  ·  Last active: 2025-06-27
Response Received 3 company response(s) High - file number match
UL SEC wrote to company 2025-04-03
AIBOTICS, INC.
File Nos in letter: 024-12597
CR Company responded 2025-05-29
AIBOTICS, INC.
Financial Reporting Business Model Clarity Regulatory Compliance
File Nos in letter: 024-12597
CR Company responded 2025-06-24
AIBOTICS, INC.
Offering / Registration Process Regulatory Compliance Financial Reporting
File Nos in letter: 024-12597
CR Company responded 2025-06-27
AIBOTICS, INC.
Offering / Registration Process Regulatory Compliance Financial Reporting
File Nos in letter: 024-12597
AIBOTICS, INC.
CIK: 0001763329  ·  File(s): 024-12597  ·  Started: 2025-05-20  ·  Last active: 2025-05-20
Awaiting Response 0 company response(s) High
UL SEC wrote to company 2025-05-20
AIBOTICS, INC.
File Nos in letter: 024-12597
AIBOTICS, INC.
CIK: 0001763329  ·  File(s): 024-11770  ·  Started: 2022-01-14  ·  Last active: 2022-01-14
Response Received 1 company response(s) High - file number match
UL SEC wrote to company 2022-01-14
AIBOTICS, INC.
File Nos in letter: 024-11770
CR Company responded 2022-01-14
AIBOTICS, INC.
Offering / Registration Process Regulatory Compliance Financial Reporting
File Nos in letter: 024-11770
AIBOTICS, INC.
CIK: 0001763329  ·  File(s): 000-56022  ·  Started: 2021-04-06  ·  Last active: 2021-04-06
Awaiting Response 0 company response(s) High
UL SEC wrote to company 2021-04-06
AIBOTICS, INC.
Regulatory Compliance Financial Reporting Internal Controls
File Nos in letter: 000-56022
AIBOTICS, INC.
CIK: 0001763329  ·  File(s): 000-56022  ·  Started: 2021-02-02  ·  Last active: 2021-02-02
Awaiting Response 0 company response(s) High
UL SEC wrote to company 2021-02-02
AIBOTICS, INC.
File Nos in letter: 000-56022
AIBOTICS, INC.
CIK: 0001763329  ·  File(s): 000-56022  ·  Started: 2019-06-13  ·  Last active: 2019-06-13
Awaiting Response 0 company response(s) High
UL SEC wrote to company 2019-06-13
AIBOTICS, INC.
Regulatory Compliance Financial Reporting Internal Controls
File Nos in letter: 000-56022
AIBOTICS, INC.
CIK: 0001763329  ·  File(s): 000-56022  ·  Started: 2019-05-07  ·  Last active: 2019-05-29
Response Received 1 company response(s) High - file number match
UL SEC wrote to company 2019-05-07
AIBOTICS, INC.
File Nos in letter: 000-56022
CR Company responded 2019-05-29
AIBOTICS, INC.
File Nos in letter: 000-56022
DateTypeCompanyLocationFile NoLink
2025-06-27 Company Response AIBOTICS, INC. NV N/A
Offering / Registration Process Regulatory Compliance Financial Reporting
Read Filing View
2025-06-24 Company Response AIBOTICS, INC. NV N/A
Offering / Registration Process Regulatory Compliance Financial Reporting
Read Filing View
2025-05-29 Company Response AIBOTICS, INC. NV N/A
Financial Reporting Business Model Clarity Regulatory Compliance
Read Filing View
2025-05-20 SEC Comment Letter AIBOTICS, INC. NV 024-12597 Read Filing View
2025-04-03 SEC Comment Letter AIBOTICS, INC. NV 024-12597 Read Filing View
2022-01-14 SEC Comment Letter AIBOTICS, INC. NV N/A Read Filing View
2022-01-14 Company Response AIBOTICS, INC. NV N/A
Offering / Registration Process Regulatory Compliance Financial Reporting
Read Filing View
2021-04-06 SEC Comment Letter AIBOTICS, INC. NV N/A
Regulatory Compliance Financial Reporting Internal Controls
Read Filing View
2021-02-02 SEC Comment Letter AIBOTICS, INC. NV N/A Read Filing View
2019-06-13 SEC Comment Letter AIBOTICS, INC. NV N/A
Regulatory Compliance Financial Reporting Internal Controls
Read Filing View
2019-05-29 Company Response AIBOTICS, INC. NV N/A Read Filing View
2019-05-07 SEC Comment Letter AIBOTICS, INC. NV N/A Read Filing View
DateTypeCompanyLocationFile NoLink
2025-05-20 SEC Comment Letter AIBOTICS, INC. NV 024-12597 Read Filing View
2025-04-03 SEC Comment Letter AIBOTICS, INC. NV 024-12597 Read Filing View
2022-01-14 SEC Comment Letter AIBOTICS, INC. NV N/A Read Filing View
2021-04-06 SEC Comment Letter AIBOTICS, INC. NV N/A
Regulatory Compliance Financial Reporting Internal Controls
Read Filing View
2021-02-02 SEC Comment Letter AIBOTICS, INC. NV N/A Read Filing View
2019-06-13 SEC Comment Letter AIBOTICS, INC. NV N/A
Regulatory Compliance Financial Reporting Internal Controls
Read Filing View
2019-05-07 SEC Comment Letter AIBOTICS, INC. NV N/A Read Filing View
DateTypeCompanyLocationFile NoLink
2025-06-27 Company Response AIBOTICS, INC. NV N/A
Offering / Registration Process Regulatory Compliance Financial Reporting
Read Filing View
2025-06-24 Company Response AIBOTICS, INC. NV N/A
Offering / Registration Process Regulatory Compliance Financial Reporting
Read Filing View
2025-05-29 Company Response AIBOTICS, INC. NV N/A
Financial Reporting Business Model Clarity Regulatory Compliance
Read Filing View
2022-01-14 Company Response AIBOTICS, INC. NV N/A
Offering / Registration Process Regulatory Compliance Financial Reporting
Read Filing View
2019-05-29 Company Response AIBOTICS, INC. NV N/A Read Filing View
2025-06-27 - CORRESP - AIBOTICS, INC.
CORRESP
 1
 filename1.htm

 June 27, 2025

 US Securities and Exchange Commission
 Attn: Joe McCann
 Division of Corporation Finance
 Office of Life Sciences
 Washington, D.C. 20549

 Re: Aibotics, Inc.
 Offering Statement on Form 1-A Filed May 7, 2025
 File No. 024-12597

 Dear Mr. McCann:
 We hereby withdraw our previous request for qualification of the above referenced Offering Statement and replace it with the following. Pursuant to Rule 252(e) promulgated under the Securities Act of 1933, as amended (the "Act"), Aibotics Inc. (the "Company") hereby requests that the Securities and Exchange Commission (the "Commission") issue a qualification order for the above referenced Offering Statement on Form 1A, so that it may be qualified by 4:00 pm., Eastern Time on Tuesday, July 1, 2025, or as soon thereafter as is practicable.
 We understand that the Commission has completed its review and has no further comments.
 The Company is aware of its responsibilities under the Act, as they relate to this offering of securities. As requested, the Company further acknowledges that:
 · Should the Commission or the staff, acting pursuant to delegated authority, qualify the filing, it does not foreclose the Commission from taking any action with respect to the filing;
 · The action of the Commission or the staff, acting pursuant to delegated authority, in qualifying the filing, does not relieve the Company from its responsibility for the adequacy and accuracy of the disclosures in the filing; and
 · The Company may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
 The Company acknowledges that the Company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
 If you have any questions, please contact our counsel, Jonathan Leinwand (954) 903-7856.
 Thank you in advance for your assistance.
 Very Truly Yours,
 AIBOTICS INC.
 By: /s/ Ben Kaplan
 Ben Kaplan, CEO
2025-06-24 - CORRESP - AIBOTICS, INC.
CORRESP
 1
 filename1.htm

 June 23, 2025

 US Securities and Exchange Commission
 Attn: Joe McCann
 Division of Corporation Finance
 Office of Life Sciences
 Washington, D.C. 20549

 Re: Aibotics, Inc.
 Offering Statement on Form 1-A Filed May 7, 2025
 File No. 024-12597

 Dear Mr. McCann:
 Pursuant to Rule 252(e) promulgated under the Securities Act of 1933, as amended (the "Act"), Aibotics Inc. (the "Company") hereby requests that the Securities and Exchange Commission (the "Commission") issue a qualification order for the above referenced Offering Statement on Form 1A, so that it may be qualified by 4:00 pm., Eastern Time on Tuesday, June 24, 2025, or as soon thereafter as is practicable.
 We understand that the Commission has completed its review and has no further comments.
 The Company is aware of its responsibilities under the Act, as they relate to this offering of securities. As requested, the Company further acknowledges that:
 · Should the Commission or the staff, acting pursuant to delegated authority, qualify the filing, it does not foreclose the Commission from taking any action with respect to the filing;
 · The action of the Commission or the staff, acting pursuant to delegated authority, in qualifying the filing, does not relieve the Company from its responsibility for the adequacy and accuracy of the disclosures in the filing; and
 · The Company may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
 The Company acknowledges that the Company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
 If you have any questions, please contact our counsel, Jonathan Leinwand (954) 903-7856.
 Thank you in advance for your assistance.
 Very Truly Yours,
 AIBOTICS INC.
 By: /s/ Ben Kaplan
 Ben Kaplan, CEO
 100 SE 2nd Street • Suite 2000 • Miami, FL 33131
 www.aibotics.ai
2025-05-29 - CORRESP - AIBOTICS, INC.
CORRESP
 1
 filename1.htm

 May 29, 2025

 Chris Edwards and Joe McCann
 US Securities and Exchange Commission
 Division of Corporation Finance
 Office of Life Sciences
 Washington, D.C. 20549

 Re: Aibotics, Inc.
 Amendment No. 1 to the Offering Statement on Form 1-A Filed May 7, 2025
 File No. 024-12597

 Ladies and Gentlemen:

 This letter is being submitted on behalf of Aibotics, Inc. (the “Company”) in response to the comment letter, dated May 20, 2025, of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) with respect to Amendment No. 1 to the Offering Statement on Form1-A filed on May 7, 2025 (the “Offering Statement”).

 Amendment No. 1 to the Offering Statement on Form 1-A Use of Proceeds, page 16

 1. Please revise the Use of Proceeds table so that it reflects the amount that could be received at the various levels of funding. Currently, the total of the amounts allotted to the individual uses listed in the table exceeds the total amount that could be raised in the offering.

 Response : The Offering Statement has been amended per the Staff’s comment and the Use of Proceeds table has been revised to reflect the amount that could be received at the various levels of funding.

 Business, page 26

 2. Please revise this section and throughout the Offering Statement to make clear the status and current plans for the Company's business operations. In this regard, the Summary section indicates that the Company's business involves the use of AI and robotics to develop innovative solutions to address real-world challenges; however, the Business section indicates that you are pursuing the development of pharmaceutical grade components for psychedelic based treatments. As applicable, disclose when the company ceased any material business operations.

 AIBotics Inc.
 May 29, 2025
 Page 2 of 2
 Response : The business overview section on page 26 as well as the rest of the offering Statement has been amended so that the current business plans for the Company’s business operations is consistently stated as follows: “AIBotics leverages AI and robotics to develop innovative solutions that address real-world challenges. Its flagship products include the Phill Robot™, an AI-powered massage robot that delivers spa-quality care with IoT integration, and Milkyway, a smart refrigerator that simplifies breast milk storage with automated organization and app connectivity”.

 Executive Compensation, page 32

 3. Please update your executive compensation table for the fiscal year ended December 31, 2024. Refer to Item 11(a) of Part II of Form 1-A.

 Response : The executive compensation table has been updated for the fiscal year ended December 31, 2024.

 Should you have any questions regarding the foregoing, please do not hesitate to contact Jonathan Leinwand at (954) 903-7856.

 Very Truly Yours,

 JONATHAN D. LEINWAND, P.A.

 By:

             Jonathan Leinwand, Esq.

 J ONATHAN D. L EINWAND , P.A.
 18305 Biscayne Blvd. • Suite 200 • Aventura, FL 33160 • Tel: (954) 903-7856 • Fax: (954) 252-4265
 www.jdlpa.com
2025-05-20 - UPLOAD - AIBOTICS, INC. File: 024-12597
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 20, 2025

Ben Kaplan
Chief Executive Officer
Aibotics, Inc.
100 SE 2nd St
Suite 2000
Miami, FL 33131

 Re: Aibotics, Inc.
 Amendment No. 1 to the Offering Statement on Form 1-A
 Filed May 7, 2025
 File No. 024-12597
Dear Ben Kaplan:

 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.

Amendment No. 1 to the Offering Statement on Form 1-A
Use of Proceeds, page 16

1. Please revise the Use of Proceeds table so that it reflects the amount
that could be
 received at the various levels of funding. Currently, the total of the
amounts allotted to
 the individual uses listed in the table exceeds the total amount that
could be raised in
 the offering.
Business, page 26

2. Please revise this section and throughout the Offering Statement to make
clear the
 status and current plans for the Company's business operations. In this
regard, the
 Summary section indicates that the Company's business involves the use
of AI and
 robotics to develop innovative solutions to address real-world
challenges; however,
 May 20, 2025
Page 2

 the Business section indicates that you are pursuing the development
 of pharmaceutical grade components for psychedelic based treatments. As
applicable,
 disclose when the company ceased any material business operations.
Executive Compensation, page 32

3. Please update your executive compensation table for the fiscal year ended
December
 31, 2024. Refer to Item 11(a) of Part II of Form 1-A.
 Please contact Chris Edwards at 202-551-6761 or Joe McCann at
202-551-6262 with
any questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Life Sciences
cc: Jonathan D. Leinwand, Esq.
</TEXT>
</DOCUMENT>
2025-04-03 - UPLOAD - AIBOTICS, INC. File: 024-12597
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 3, 2025

Ben Kaplan
Chief Executive Officer
Aibotics, Inc.
100 SE 2nd St
Suite 2000
Miami, FL 33131

 Re: Aibotics, Inc.
 Offering Statement on Form 1-A
 Filed April 2, 2025
 File No. 024-12597
Dear Ben Kaplan:

 Our initial review of your offering statement indicates that it fails
in material respects
to comply with the requirements of Regulation A and Form 1-A. More
specifically, we note
that your filing does not include audited financials for the fiscal year ended
December 31,
2024.

 We will provide more detailed comments relating to your offering
statement
following our review of a substantive amendment that addresses this deficiency.

 Please contact Joe McCann at 202-551-6262 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Jonathan D. Leinwand, Esq.
</TEXT>
</DOCUMENT>
2022-01-14 - UPLOAD - AIBOTICS, INC.
United States securities and exchange commission logo
January 14, 2022
Ben Kaplan
Chief Executive Officer
Mycotopia Therapies, Inc.
18851 NE 29th Ave.
Suite 700
Aventura, FL 33180
Re:Mycotopia Therapies, Inc.
Form 1-A
Filed January 6, 2022
File No. 024-11770
Dear Mr. Kaplan:
            This is to advise you that we do not intend to review your offering statement.
            We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff. We also remind you that, following qualification of your Form 1-A, Rule 257
of Regulation A requires you to file periodic and current reports, including a Form 1-K which
will be due within 120 calendar days after the end of the fiscal year covered by the report.
            Please contact Ryan Lichtenfels at 202-551-3001 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Jonathan Leinwand
2022-01-14 - CORRESP - AIBOTICS, INC.
CORRESP
1
filename1.htm

January 14, 2022

United States Securities

and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

Attn: Ryan Lichtenfels

Washington, D.C. 20549

Re: Mycotopia Therapies, Inc.

Form 1-A

Filed January 6, 2022

File No. 024-11770

Dear Mr. Lichtenfels:

Pursuant to Rule 252(e) promulgated under the Securities Act of 1933, as amended (the "Act"), Mycotopia Therapies, Inc. (the "Company") hereby requests that the Securities and Exchange Commission (the "Commission") issue a qualification order for the above referenced Offering Statement on Form 1A, so that it may be qualified by 4:00 pm., Eastern Time on Tuesday, January 18, 2022, or as soon thereafter as is practicable.

We understand that the Commission has completed its review and has no further comments.

The Company is aware of its responsibilities under the Act, as they relate to this offering of securities. As requested, the Company further acknowledges that:

·Should the Commission or the staff, acting pursuant to delegated authority, qualify the filing, it does not foreclose the Commission from taking any action with respect to the filing;

·The action of the Commission or the staff, acting pursuant to delegated authority, in qualifying the filing, does not relieve the Company from its responsibility for the adequacy and accuracy of the disclosures in the filing; and

·The Company may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

The Company acknowledges that the Company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

If you have any questions, please contact our counsel, Jonathan Leinwand (954) 903-7856.

Thank you in advance for your assistance.

Very Truly Yours,

MYCOTOPIA THERAPIES, INC.

By:/s/ Ben Kaplan

      Ben Kaplan, CEO
2021-04-06 - UPLOAD - AIBOTICS, INC.
United States securities and exchange commission logo
April 6, 2021
Benjamin Kaplan
President
20/20 Global, Inc.
18851 NE 29th Avenue, Suite 700
Aventura, FL 33180
Re:20/20 Global, Inc.
Form 8-K
Filed January 20, 2021
File No. 000-56022
Dear Mr. Kaplan:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Jonathan Leinwand, Esq.
2021-02-02 - UPLOAD - AIBOTICS, INC.
United States securities and exchange commission logo
February 2, 2021
Benjamin Kaplan
President
20/20 Global, Inc.
18851 NE 29th Avenue, Suite 700
Aventura, FL 33180
Re:20/20 Global, Inc.
Form 8-K
Filed January 20, 2021
File No. 000-56022
Dear Mr. Kaplan:
            We have reviewed your filing and have the following comment.  In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
            Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 8-K filed January 19, 2021
General
1.Please tell us whether you believe that you have ceased to be a shell company, as defined
under Rule 12b-2 of the Exchange Act, as a result of the transactions that you have
entered into with Ehave, Inc., including your ownership of Mycotopia Therapies Inc., and
its ownership interest in PsychedeliTech, Inc.  Please provide us with a detailed legal
analysis in support of your position.  For guidance, please refer to SEC Release No. 33-
8587.  If you determine that you ceased to be a shell company, please amend your filing to
include the disclosure required by Items 2.01(f), 5.01(a)(8), and 5.06 of Form 8-K.

 FirstName LastNameBenjamin Kaplan
 Comapany Name20/20 Global, Inc.
 February 2, 2021 Page 2
 FirstName LastName
Benjamin Kaplan
20/20 Global, Inc.
February 2, 2021
Page 2
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact Cara Wirth at (202) 551-7127 or Dietrich King at (202) 551-8071 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Jonathan Leinwand, Esq.
2019-06-13 - UPLOAD - AIBOTICS, INC.
June 13, 2019
Mark Williams
President and Chief Executive Officer
20/20 Global, Inc.
480 22nd Street, Box 2
Heyburn, ID 83336
Re:20/20 Global, Inc.
Form 10-12G
Filed April 15, 2019
File No. 000-56022
Dear Mr. Williams:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Consumer Products
2019-05-29 - CORRESP - AIBOTICS, INC.
CORRESP
1
filename1.htm

20/20 GLOBAL, INC.

May 29, 2019

VIA EDGAR

Scott Anderegg, Staff Attorney

Division of Corporation Finance

U.S. Securities and Exchange Commission

Washington, D.C. 20549

Re:20/20 Global, Inc.

Form 10-12G filed April 15, 2019

File No. 000-56022

Dear Mr. Anderegg:

This letter is in response to your comments by letter of May 7, 2019. We have set forth your comments below, immediately followed by our responses.

Form 10 Filed April 15, 2019

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 10

1.Please refer to your analysis of results of operations beginning on page 10. Please revise your disclosure concerning the fluctuations in revenue, gross profit, and general and administrative expenses to provide your readers with management's insight into why these items increased or decreased from 2017 to 2018 rather than merely repeating the dollar amounts seen on the face of your statements of operations. Refer to Item 303 of Regulation S-K.

Response:We have revised the disclosure.

Exhibit 3.02 Bylaws of 20/20 Global, Inc.

2.We note that the forum selection provision in your bylaws identities the state or federal court of Utah as the exclusive forum for certain litigation, including any “derivative action.” Please disclose whether this provision applies to actions arising under the Securities Act or Exchange Act. In this regard, we note that Section 27 of the Exchange Act creates exclusive federal jurisdiction over all suits brought to enforce any duty or liability created by the Exchange Act or the rules and regulations thereunder, and Section 22 of the Securities Act creates concurrent jurisdiction for federal and state courts over all suits brought to enforce any duty or liability created by the Securities Act or the rules and regulations thereunder. If the provision applies to Securities Act claims, please revise your disclosures to disclose this information and to state that there is uncertainty as to whether a court would enforce such provision, and to state that stockholders will not be deemed to have waived the company’s compliance with the federal securities laws and the rules and regulations under it.

480 22ND St. Heyburn, ID 83336 USA

Phone: 208.677.2020

20/20 GLOBAL, INC.

Scott Anderegg, Staff Attorney

Division of Corporation Finance

U.S. Securities and Exchange Commission

May 29, 2019

Page 2

___________________________________

Response:We have revised the disclosure.

We would be happy to provide additional information you may request or respond to further inquiries.

Sincerely,

20/20 GLOBAL, INC.

/s/ Mark Williams

Mark Williams

President and Chief Executive Officer
2019-05-07 - UPLOAD - AIBOTICS, INC.
May 7, 2019
Mark Williams
President and Chief Executive Officer
20/20 Global, Inc.
480 22nd Street, Box 2
Heyburn, ID 83336
Re:20/20 Global, Inc.
Form 10-12G
Filed April 15, 2019
File No. 000-56022
Dear Mr. Williams:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments.
Form 10 Filed April 15, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
10
1.Please refer to your analysis of results of operations beginning on page 10.  Please revise
your disclosure concerning the fluctuations in revenue, gross profit, and general and
administrative expenses to provide your readers with management's insight into why these
items increased or decreased from 2017 to 2018 rather than merely repeating the dollar
amounts seen on the face of your statements of operations.  Refer to Item 303 of
Regulation S-K.
Exhibit 3.02 Bylaws of 20/20 Global, Inc
2.We note that the forum selection provision in your bylaws identifies the state or federal
court of Utah as the exclusive forum for certain litigation, including any ``derivative

 FirstName LastNameMark Williams
 Comapany Name20/20 Global, Inc.
 May 7, 2019 Page 2
 FirstName LastName
Mark Williams
20/20 Global, Inc.
May 7, 2019
Page 2
action.´´ Please disclose whether this provision applies to actions arising under the
Securities Act or Exchange Act. In this regard, we note that Section 27 of the Exchange
Act creates exclusive federal jurisdiction over all suits brought to enforce any duty or
liability created by the Exchange Act or the rules and regulations thereunder, and Section
22 of the Securities Act creates concurrent jurisdiction for federal and state courts over all
suits brought to enforce any duty or liability created by the Securities Act or the rules and
regulations thereunder. If the provision applies to Securities Act claims, please revise your
disclosures to disclose this information and to state that there is uncertainty as to whether
a court would enforce such provision, and to state that stockholders will not be deemed to
have waived the company’s compliance with the federal securities laws and the rules and
regulations under it.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Jennifer Thompson, Accounting Branch Chief, at 202-551-3737 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Scott Anderegg, Staff Attorney, at 202-551-3342 or Jennifer López-Molina, Staff
Attorney,  at 202-551-3792 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Consumer Products