Duo World, Inc.
170 S. Green Valley Parkway
Suite 300
Henderson, NV 89012
September 12, 2016
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
Attention: | Ms. Kathleen Collins |
| Accounting Branch Chief |
| Mr. Frank Knapp Staff Accountant Bernard Nolan, Esq. Attorney-Advisor Gabriel Eckstein, Esq. Attorney-Advisor |
Re: | Duo World, Inc. Amendment Nos. 2 and 3 to Registration Statement on Form S-1 Amendment No. 2 filed on August 12, 2016 Amendment No. 3 filed on August 15, 2016 File No. 333-2114602 |
Dear Madams and Sirs:
On August 29, 2016, our attorney, David E. Wise, Esq., received certain verbal comments from the Staff related to Amendment Nos. 2 and 3 of our Form S-1.
Responses to Staff’s Verbal Comments
In response to the verbal comments, we have revised our filing as follows:
| 1. | We have revised our disclosure in the first paragraph of the cover page of the prospectus to be consistent with our disclosure under “THE OFFERING – Initial Offering Price” on page 3 of our amended filing, under “DETERMINATION OF OFFERING PRICE” on page 17 of our amended filing, and under “PLAN OF DISTRIBUTION” on page 18 of our amended filing, to state that: |
“The selling shareholders may only sell their shares of our common stock using this prospectus at $1.00 per share until our shares are quoted on the OTC Bulletin Board and thereafter at prevailing market prices or privately negotiated prices.”
| 2. | We have revised our disclosures related to our emerging growth company status on the cover page of our prospectus and on page 3 of our amended filing to also discuss the availability of reduced or scaled disclosure requirements in the event that we are a smaller reporting company after we cease being an emerging growth company. |
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| 3. | We have refiled Exhibits 10.3 through 10.17 in searchable text format. |
| 4. | We have revised the heading of section in our MD&A disclosure on page 37 of our amended filing to reflect the appropriate periods covered (“Results for the three months ended June 30, 2016, and June 30, 2015”). |
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| 5. | We have deleted the “Recent Accounting Pronouncements” disclosure paragraph from our MD&A disclosure (which was on page 44 of Amendment No. 3). |
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| 6. | We have also made some minor updates to our disclosure under “DESCRIPTION OF BUSINESS” on pages 29-32 of our amended filing. |
Please address any further comments and questions related to our amended filing to our attorney, David E. Wise, Esq., whose contact information is set forth below:
Law Offices of WiseLaw, P.C.
The Colonnade
9901 IH-10 West, Suite 800
San Antonio, Texas 78230
(210)558-2858
wiselaw@verizon.net
Sincerely, | |
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Duo World, Inc. | |
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By: | /s/ Muhunthan Canagasooryam | |
| Muhunthan Canagasooryam | |
| President | |