| December 14, 2018 |
Via Edgar:
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Consumer Products
100 F Street, N.E.
Washington, DC 20549
| Re: | GSRX Industries Inc. | |
| Form 10-Q for Fiscal Quarter Ended September 30, 2018 | ||
| Filed October 31, 2018 | ||
| Response Dated November 19, 2018 | ||
| File No. 333-141929 |
Dear Ms. Guobadia:
On behalf of GSRX Industries Inc. (the “Company”), please accept this letter as the Company’s response to the comments of the reviewing staff of the U.S. Securities and Exchange Commission (the “Staff”) in connection with the above-referenced submission as set forth in the comment letter dated as of December 3, 2018. For ease of reference, the Staff’s comments are repeated below, and are followed by the Company’s responses in italics.
Form 10-Q for Fiscal Quarter Ended September 30, 2018
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies Inventory, page 10
| 1. | We reviewed your proposed disclosure in response to comment 2.Please disclose the basis of stating inventories in future filings.Refer to ASC 330-10-50-1 and paragraph 6(b) of Rule 5-02 of Regulation S-X. |
Response:
The Company respectfully acknowledges the Staff’s comment. In future filings, the Company will include similar disclosure language as follows:
The Company’s inventory is comprised of the following items:
| As of September 30, 2018 | As of December 31, 2017 | |||||||
| Raw materials | $ | - | $ | - | ||||
| Work-in-Progress | - | - | ||||||
| Finished goods | 839,807 | - | ||||||
| Total | $ | 839,807 | $ | - | ||||
Finished goods consists of cannabis, such as flower, and cannabis-related products and accessories, such as packaged goods, edibles, creams, oils, pipes, bowls and cartridges. Inventory is computed using the first-in-first-out (FIFO) cost method and is stated at the lower of cost or market. Inventory is written down for any obsolescence or when the net realizable value of inventory is less than the carrying value. For the three and nine months ended September 30, 2018, the Company did not record write-downs related to inventory in cost of sales.
Please do not hesitate to contact the undersigned if you have any questions or comments. Thank you.
| Very truly yours, | ||
| /s/ Thomas Gingerich | ||
| Thomas Gingerich | ||
| Chief Financial Officer | ||
| cc. | Darrin M. Ocasio, Esq. | |
| Sichenzia Ross Ference LLP |
| 2 |
