September 3, 2019
Alex Cunningham
Chief Executive Officer
Cardiff Lexington Corp
401 Las Olas Blvd., Unit 1400
Ft. Lauderdale, FL 33301
Re: Cardiff Lexington Corporation
Form 10-K for Fiscal Year Ended December 31, 2018
Filed April 16, 2019
Form 10-Q for Fiscal Quarters Ended June 30, 2019
Filed August 20, 2019
File No. 000-49709
Dear Mr. Cunningham:
We have reviewed your filing and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your
disclosure.
Please respond to this comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to this comment, we may have additional
comments.
Form 10-Q for Fiscal Quarters Ended June 30, 2019
Note 3. Acquisitions, page 14
1. Please tell us your consideration of the guidance in Rules 8-04 and 8-05
of Regulation S-
X as it relates to the acquisition of JM Enterprise 1, Inc., which
closed on May 8, 2019.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
You may contact Joseph Cascarano, Staff Accountant, at (202) 551-3376
or Robert S.
Littlepage, Accountant Branch Chief, at (202) 551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact Larry
Spirgel, Assistant
Director, at (202) 551-3815 with any other questions.
Alex Cunningham
Cardiff Lexington Corp
September 3, 2019
Page 2
FirstName LastNameAlex Cunningham Sincerely,
Comapany NameCardiff Lexington Corp
Division of Corporation Finance
September 3, 2019 Page 2 Office of Telecommunications
FirstName LastName