VIA E-MAIL
Division of Corporation Finance
Office of Healthcare & Insurance
United States Securities and Exchange Commission
Washington, D.C. 20549
Re: Apex 11 Inc.
Registration Statement on Form 10
Filed December 18, 2018
File No. 000-54964
Dear Mr. Iarocci:
The following is response to the comment letter received on February 12th, 2019.
Registration Statement on Form 10
1. | Include an additional risk factor highlighting your history as public reporting blank check company and your subsequent revocation of Securities Exchange Act registration due to failure to file required reports. Highlight the possibly of undisclosed liabilities that may exist due to your prior existence as a public company. |
Additional risk factor added.
There is competition for those private companies suitable for a merger transaction of the type contemplated by our management., page 11
2. | Please revise to address, if true, that Apex 11 may compete for acquisitions with majority share holder DCA Asset Management, Inc. If so, please address how management would address any conflicts in allocating acquisition opportunities. |
Disclosure added that Apex 11 may compete with acquisitions with majority shareholder DCA Asset Management, Inc, and that Apex 11 shall be given priority as to any operational entities.
Financial Statements for the Six Months ended June 30th, 2018. Page F-10
3. | Please update your filing to include interim period financial statements as of and for the nine months ended September 30th, 2018 and 2017. |
Updated Financials Included.
Sincerely, |
____________________________ |
Anthony J. Iarocci, Jr.
DCA Asset Management, Inc.
cc: | Kathryn Jacobson, Senior Staff Accountant |
Robert S. Littlepage, Accounting Branch Chief
Paul Fischer, Staff Attorney
Larry Spirgel, Assistant Director