REFLECT SCIENTIFIC, INC.
1266 SOUTH 1380 WEST
OREM, UTAH 84058
June 8, 2021
Securities and Exchange Commission
Division of Corporation Finance
Office of Life Sciences
Washington, DC 20549
Attn: Deanna Virginio, Esq.
Re:
Reflect Scientific, Inc., a Utah corporation (the “Company”)
Amendment No. 4 to Registration Statement on Form 10
Filed June 1, 2021
Commission File No. 000-31377
Dear Ms. Virginio:
In response to your letter June 7, 2021, the Company provides its response to your comment as detailed below:
1.
We note your response to our prior comment and the revised disclosure on page 7, notably your statement regarding “anomalies.” In this regard, please clarify whether the customer that represented 46.2% of revenues for the first quarter of 2021 was also a major customer for the fiscal years ended 2020 and 2019. To the extent that such customer consistently represents a material amount of revenues, please identify the customer and include disclosure that describes the potential impact of the loss of such customer on the company. Alternatively, please explain to us why you do not believe the company is dependent on this customer. See Item 101(h)(4)(iv) of Regulation S-K.
The customer that represented 46.2% of revenues for the first quarter of 2021 was not also a major customer for the fiscal quarters ended 2020 and 2019. Management does not believe that the Company is dependent on this customer because, prior to the first quarter of 2021, it had never been a customer of the Company before and management has no reason to believe that the customer will represent a material amount of revenues in the future.
Please advise whether you will have any further comments on this filing.
REFLECT SCIENTIFIC, INC.
By /s/ Kim Boyce
Kim Boyce, Chief Executive Officer