United States securities and exchange commission logo
October 30, 2020
David Lazar
Chief Executive Officer
Zyrox Mining International, Inc.
1185 Avenue of the Americas, 3rd Floor
New York, NY 10036
Re: Zyrox Mining
International, Inc.
Amendment No. 1 to
Registration
Statement on Form 10
Filed October 19,
2020
File No. 000-56204
Dear Mr. Lazar:
We have reviewed your filing 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 these comments 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
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response and any amendment you may file in
response to these
comments, we may have additional comments.
Amendment No. 1 to Registration Statement on Form 10
Item 1A. Risk Factors, page 7
1. We note your revised
disclosure on page 17 in response to prior comment 3. It appears
that a business
combination has yet to occur for each of the companies that you have
identified as blank
check companies currently or formerly under Mr. Lazar's control.
Please add risk factor
disclosure highlighting Mr. Lazar's lack of experience
identifying and closing
potential business combination transactions.
David Lazar
FirstName LastNameDavid Lazar
Zyrox Mining International, Inc.
Comapany
October 30,NameZyrox
2020 Mining International, Inc.
October
Page 2 30, 2020 Page 2
FirstName LastName
Item 4. Security Ownership of Certain Beneficial Owners and Management , page
16
2. We note your disclosure that it is unlikely that the Company's
controlling
stockholders could exert any influence on Management s activities
due to Mr. Lazar s
position as the Company s sole officer and director as well as the
Company remaining
under his control as the court-appointed custodian. Please revise your
disclosure to clarify
the control that is afforded to Mr. Lazar as a court-appointed
custodian of the Company,
especially with regard to corporate actions that require stockholder
approval.
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 Vanessa Robertson at 202-551-3649 or Lisa Vanjoske at
202-551-3614
if you have questions regarding comments on the financial statements and
related
matters. Please contact Deanna Virginio at 202-551-4530 or Suzanne Hayes at
202-551-3675
with any other questions.
Sincerely,
Division of
Corporation Finance
Office of Life
Sciences
cc: Dave Natan