GOLDEN GLOBAL CORP.
22106 Montebello Drive
Boca Raton, FL 33433
April 26, 2016
Mail Stop3561
VIA EDGAR
United States Securities and Exchange Commission
Washington, D.C.
Attention: | Jonathan Burr |
David Link |
Re: | GoldenGlobal Corp. (the “Company”) | |
Preliminary Information Statement on Schedule 14C | ||
Filed March 18, 2016 | ||
File No. 000-54528 |
Gentlemen:
The following sets forth the Company’s response to the Staff’s comment letter dated March 31, 2016 with respect to the above-referenced filing. For the Staff’s convenience, the response to each comment follows the comment itself.
General
Comment:
1. We note that onOctober30, 2015 you entered into an acquisition agreementto acquire Corpaycar, LLCand that Corpaycaris now yourwholly-owned subsidiary. Please advise us as to when you intendto file the Item2.01Form 8-K thatwasrequired when you completed the acquisition. Also advise us when you intendto file thefinancial statements fortheCorpaycaracquisition. See Item 9.01(a)(4)ofForm8-K.
Response:
The Company respectfully calls the attention to the Staff that on April 20, 2016, the Company filed a Current Report on Form 8-K with the Securities and Exchange Commission (the “Commission”), wherein it disclosed that the Company, under new management, had entered into an agreement with the sole member of Corpaycar, LLC, to rescind the previously reported October 30, 2015 acquisition agreement and the transactions contemplated thereby,ab initio, as of the October 30, 2015 date. Accordingly, the Company believes that it is not required to file the financial statements referred to in the Staff’s comment.
As further disclosed in aforementioned Current Report on Form 8-K, the Company intends to focus its business efforts on creating and integrating a platform of complementary fitness industry businesses, including the recently announced proposed acquisition of the membership base and operating assets of three northern Ohio fitness centers, which it intends to rebrand as Global Fitness™ training centers and the establishment of its NUTRASTAX™ Fitness Supplement Division, through which it intends to market and sell a line of fitness supplements under the NURTRASTAX™ brand through its Global Fitness™ training centers and other distribution channels.
Comment:
2. Please advise us astowhen you intend to become current with your Securities Exchange Act of1934filing obligations.We note, for example, thatyou have not filed yourannual report on Form10-K for the year ended June 30,2015 and have notfiled quarterly reports on Form10-Q forthe two quarterlyperiods ended September 30, 2015 and December31, 2015.
Response:
We respectfully call the Staff’s attention to the fact that on April 14, 2016 the Company filed its Annual Report on Form 10-K for the fiscal year ended June 30, 2015 with the Commission. The financial statements to be included in the Company’s Quarterly Reports on Form 10-Q for the quarters ended September 30, 2015 and December 31, 2015 are currently being reviewed by the Company’s auditors and the Company anticipates filing its past due report within ten (10) days of the date of this letter.
The Company hereby acknowledges to the Staff that:
• theCompanyis responsiblefortheadequacyandaccuracy of thedisclosureinthe filing;
• Staffcomments orchanges to disclosurein response to Staff comments donot foreclose the Commission fromtakinganyaction with respectto thefiling; and
• theCompanymaynot assert Staffcomments as adefense inany proceeding initiatedby the Commission or anyperson under the federalsecurities lawsof the United States.
Please feel free to contact our counsel, Dale S. Bergman, Esq. of Gutiérrez Bergman Boulris, P.L.L.C at 305.358.5100 if you have any questions with respect to the foregoing.
Very truly yours,
GOLDEN GLOBAL CORP.
By: | /s/ Erik Blum |
Erik Blum | |
Chief Executive Officer |