LAW – WEST
ANDERSON CALL & WILKINSON
A PROFESSIONAL CORPORATION
110 SOUTH REGENT STREET, SUITE 200
SALT LAKE CITY, UTAH 84111
TELEPHONE: (801) 521-3434
FAX: (801) 220-0625
August 31, 2018
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
Attention: Sherry Haywood, Staff Attorney
Re:
Geo Point Resources, Inc.
Amendment No. 2 to Information Statement on Schedule 14C
Filed August 31, 2018
File No. 000-55150
Dear Ms. Haywood:
This letter responds to the Commission’s comment letter of August 21, 2018. Geo Point Resources, Inc. has filed Amendment No. 2 to its Information Statement on Schedule 14C which contains changes responsive to the Commission’s comment.
Comment - General
Please amend your filing to include updated interim financial statements of TORtec all required financial statements of Geo Point Resources, Inc. Refer generally to Item 14(c) of Schedule 14A.
Response to Comment
TORtec Group was acquired by Geo Point Resources, Inc. on December 4, 2017. Since that date TORtec Group has been a wholly-owned subsidiary of Geo Point Resources, Inc., and the financial statements for the two companies have been prepared on a consolidated basis, and filed with the Annual and Quarterly Reports of Geo Point Resources, Inc. As a result, and to respond to the Commission’s comment, Geo Point has added a sentence in the following sections of the Schedule 14C: Financial Statements of TORtec Group, Unaudited Pro Forma Financial Statements of the Company and TORtec Group, and Additional Information, which reads as follows:
“For more recent consolidated financial statements of Geo Point Resources, Inc. which are consolidated with its wholly-owned subsidiary, TORtec Group, please refer to the Annual Report of Geo Point Resources, Inc. for the period ended March 31, 2018, and the Quarterly Report of Geo Point Resources, Inc. for the period ended June 30, 2018, which are incorporated herein by this reference and made a part hereof.”
U.S. Securities and Exchange Commission
Division of Corporation Finance
Attention: Sherry Haywood, Staff Attorney
August 31, 2018
Page 2
Additional Changes
The “August” dates in the filing have been changed to “September” in anticipation that this filing will clear the Commission’s review soon.
If you have any questions concerning this letter, please let me know
Sincerely,
/s/ Robert N. Wilkinson
Robert N. Wilkinson
RNW/mh
cc: Stephen H. Smoot
LTRS/7643