| Graubard Miller The Chrysler Building 405 Lexington Avenue New York, N.Y. 10174-1101 (212) 818-8800 | |
facsimile | | direct dial number |
(212) 818-8881 | | (212) 818-8610 |
| | email address |
| | bross@graubard.com |
June 4, 2019
Division of Corporation Finance
Office of Transportation and Leisure
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Chicken Soup for the Soul Entertainment, Inc. |
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed April 1, 2018
File No. 001-38125
Ladies and Gentlemen:
On behalf of Chicken Soup for the Soul Entertainment, Inc. (the “Company”), we respond as follows to the Staff’s comment letter dated May 30, 2019, relating to the above-captioned Annual Report on Form 10-K (“Form 10-K”). Please note that for the Staff’s convenience, we have recited the Staff’s comment and provided the Company’s response immediately thereafter.
Form 10-K for the fiscal year ended December 31, 2018
Item 9A. Controls and Procedures
Management’s Report on Internal Control over Financial Reporting, page 34
1. You disclose you do not include a report of management’s assessment regarding internal control over financial reporting due to a transition period established by the SEC for newly public companies. Please note this transition pertains to only the first Form 10-K filed after the initial public offering. Please amend your filing to include the information required by Item 308(a) of Regulation S-K in regard to management's annual report on internal control over financial reporting.
We have revised the disclosure in the Form 10-K as requested.
*************
Securities and Exchange Commission
June 4, 2019
Page 2
If you have any questions, please do not hesitate to contact me at the above telephone and facsimile numbers.
| Sincerely, |
| |
| /s/ Brian Ross |
| |
| Brian Ross |