Collectable Sports Assets, LLC
333 Westchester Avenue
Suite W21000
White Plains, NY 10604
January 29, 2021
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC. 20549
Attn: Cara Wirth
| Re: | Collectable Sports Assets, LLC | |
Offering Statement on Form 1-A Post-qualification Amendment No. 7 Filed December 30, 2020 | ||
| File No. 024-11178 |
Ladies and Gentlemen:
We hereby submit the response of Collectable Sports Assets, LLC (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission set forth in the Staff’s letter, dated January 26, 2021, providing the Staff’s comment with respect to the Company’s Post-Qualification Amendment No. 7 to Offering Statement on Form 1-A (the “Offering Statement”).
For the convenience of the Staff, the Staff’s comment is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.
Post-Qualification Amendment No. 7 to Offering Statement on Form 1-A
Principal Interest Holders, page 244
| 1. | We note your statement that “[a]s of the date of this filing, the Company has not issued any securities.” Please revise to update this section with respect to each class of your voting securities, including securities issued to the asset sellers, if applicable. Refer to Item 12 of Form 1-A. |
Response: We acknowledge the Staff’s comment and have updated the Offering Statement through the filing of Post-Qualification Amendment No. 8 (the “Amended Offering Statement”) to indicate that the Company does not have outstanding any class of voting securities. We understand “voting securities,” per Exchange Act Rule 12b-2, to mean “securities the holders of which are presently entitled to vote for the election of directors.” No holders of any series of interests that the Company is issuing have such
United States Securities and Exchange Commission
January 29, 2021
Page 2
rights. Accordingly, no additional disclosure is required other than to clarify that the statement was meant to refer to “voting” securities.
Note that in Post-Qualification Amendment No. 8, in addition to addressing the Staff’s comment, we also have added a number of new Series following the same format as we have in previous filings. We trust that this will not be problematic and, in accordance with your comment letter, we hereby request that the Commission approve the qualification of the Amended Offering Statement as soon as is practicable.
We request that we be notified of such qualification by a telephone call to our counsel, Gary M. Brown at (615) 664-5330. If you would like to discuss our response to the Staff’s comment or any other matter, please contact the undersigned at (914) 372-7337 or Mr. Brown at the number indicated
| Sincerely, | |||
| Collectable Sports Assets, LLC | |||
| By: CS Asset Manager, LLC, its managing member | |||
| By: | /s/ Ezra Levine | ||
| Ezra Levine | |||
| Chief Executive Officer | |||
| cc: | Gary M. Brown |
