BARNETT & LINN | ||
ATTORNEYS AT LAW | ||
1600 E. Florida Avenue, Suite 214 • Hemet, CA 92544 | ||
www.barnettandlinn.com | ||
WILLIAM B. BARNETT | TELEPHONE: 818-436-6410 | |
Attorney/Principal | FACSIMILE: 818-223-8303 | |
wbarnett@wbarnettlaw.com |
January 27, 2021
Division of Corporation Finance
Office of Technology
Securities and Exchange Commission
100 F Street NE
Washington D.C. 20549
Attn: | Jan Woo, Legal Branch Chief |
Jeff Kauten, Staff Attorney | |
Robert Littlepage, Accounting Branch Chief | |
Katheryn Jacobson, Staff Accountant |
Re: | Powerdyne International, Inc. (“Registrant” and/or “Company”) | |
Amendment No. 5 to Registration Statement on Form 10 | ||
Filed on October 6, 2020 | ||
File No. 000-53259 |
Gentlepersons:
The Registrant hereby files its Amendment No. 5 to Registration Statement on Form 10 (“Amendment No. 5”). The Amendment No. 5 has been revised in accordance with the Commission’s oral comment on January 26, 2021
To assist the staff in its review of Registrant’s responses, we have provided a copy of Amendment No. 5 “marked to show changes”, and our response below corresponds to the oral comment.
Executive Compensation, page 12
1. | In accordance with your comment, we have added information regarding “Executive Compensation” for the year ended December 31, 2020. | |
2. | We have also updated the “Outstanding Equity Awards at Fiscal Year End” section on page 12 to “2020”. |
We believe that we have responded to all your comments fairly and reasonably. Please do not hesitate to contact the undersigned as soon as possible should you have any further questions or comments.
Thank you for your cooperation and courtesies in this matter.
Very truly yours, | |
Barnett & Linn | |
William B. Barnett | |
WBB: lg | |
cc/ Mr. O’Rourke, CEO |