Michael A. Littman
Attorney at Law
P.O. Box 1839
Arvada, CO 80001
720-530-6184
malattyco@aol.com
July 7, 2016
United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 3561
Washington, D.C. 20549
Re: Rich Cigars, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed May 13, 2016
File No. 333-199452
Mr. Dobbie:
In addition to the requested addition of the March 31, 2016 financials, we are outlining a minor change to the Audited Financials for the Years Ended December 31, 2015 and December 31, 2014. If you feel that we need to add additional disclosures regarding the change, please let us know so that we can make the change as soon as possible. Below is a brief summary of the changes to the Audited Financials for the Years Ended December 31, 2015 and December 31, 2014.
The Assets category of the Balance Sheet was broken down into one more category, separating out Intangible Assets from the Property and Equipment. The Notes to the Financials were also adjusted to reflect the changes below.
Comparison of Changes to the Audited Financials
for the Years Ended December 31, 2015 and December 31, 2014
December 31, 2015 | December 31, 2014 | December 31, 2015 As amended | December 31, 2014 As amended | |
Balance Sheets | ||||
ASSETS | ||||
Current Assets: | ||||
Cash and cash equivalents | $ 7,056 | $ - | $ 7,056 | $ - |
Inventory | 2,947 | 2,947 | ||
Prepaid expenses | 12,498 | 1,274 | 12,498 | 1,274 |
Total current assets | 22,501 | 1,274 | 22,501 | 1,274 |
Property and Equipment, net | 9,850 | 10,276 | 1,350 | 1,776 |
Intangible Assets, net | 8,500 | 8,500 | ||
Total assets | $ 32,351 | $ 11,550 | $ 32,351 | $ 11,550 |
Other than the above changes, the financial statements for the period ended March 31, 2016 were added, along with corresponding summary info and MD&A, and dates were updated throughout the S-1.
We hope these revisions are satisfactory. If there are any disclosures that should be added as a result of this change, please inform as.
Sincerely,
/s/ Michael A. Littman
Michael A. Littman
