United States securities and exchange commission logo
September 10, 2020
Robert Striar
Chief Executive Officer
Bull Horn Holdings Corp.
801 S. Pointe Drive, Suite TH-1
Miami Beach, Florida 33139
Re: Bull Horn Holdings
Corp.
Amendment No. 3 to
Draft Registration Statement on Form S-1
Submitted August
21, 2020
CIK No. 0001759186
Dear Mr. Striar:
We have reviewed your amended draft registration statement and
have the following
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure.
Please respond to this letter by providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
believe an amendment is appropriate, please tell us why in your
response.
After reviewing the information you provide in response to these
comments and your
amended draft registration statement or filed registration statement, we
may have additional
comments.
Form S-1 DRS/A filed August 21, 2020
Summary Financial Data, page 17
1. Your narrative
descriptions in the footnotes to the table presented here indicate the "As
Adjusted" column
considers actual shareholders' equity ($15,425), the unit offering ($75
million), private
placement warrants ($3 million), cash held outside the trust account ($1
million), and deferred
underwriting costs ($2.25 million). It appears the "As Adjusted"
column represents the
aggregation of the adjustments as opposed to June 30, 2020 actual
figures adjusted to
represent the impact of the offering. Please revise or advise.
2. It appears that your
narrative identifies that working capital and net assets include $1
million held outside
the trust and $3 million in private placement notes, but does not
indicate that it also
includes the underwriting discount and offering expenses, aggregating
Robert Striar
Bull Horn Holdings Corp.
September 10, 2020
Page 2
$2 million. Please revise this discussion to either state that it
includes net proceeds of $76
million or include disclosure that the underwriting discount of $1.5
million and offering
expenses of $0.5 million are considered in this calculation.
3. Please also revise your disclosure to specify that the $1 million held
outside the trust is
included in the gross proceeds of the unit offering and private
placement warrants.
4. Finally, please support the inclusion of the June 30, 2020 equity
balance of $15,245 in the
As Adjusted working capital and total asset balances as of June 30,
2020.
You may contact Amy Geddes at 202-551-3304 or Jim Allegretto at
202-551-3849 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Scott Anderegg at 202-551-3342 or Jennifer Lopez-Molina at 202-551-3792
with any
other questions.
FirstName LastNameRobert Striar Sincerely,
Comapany NameBull Horn Holdings Corp.
Division of
Corporation Finance
September 10, 2020 Page 2 Office of Trade
& Services
FirstName LastName