United States securities and exchange commission logo
February 25, 2021
Ernest Hemple
Chief Executive Officer
Hoop Street Center I Corp
20715 S 184th Place
Queen Creek, AZ 85142
Re: Hoop Street Center
I Corp
Amendment No. 5 to
Offering Statement on Form 1-A
Filed February 18,
2021
File No. 024-11349
Dear Mr. Hemple:
We have reviewed your amended offering 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 amending your offering statement
and providing the
requested information. 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 any amendment to your offering statement and the
information you
provide in response to these comments, we may have additional comments.
Unless we note
otherwise, our references to prior comments are to comments in our
February 10, 2021 letter.
Amendment No. 5 to Offering Statement on Form 1-A
Marketing and Promotion, page 26
1. We note your response
and revised disclosure in response to Comment 2. Where you
discuss marketing your
deal after your offering statement is qualified, please remove
references to the
requirements of Rule 255, as that rule only applies to solicitations of
interests and other
communications prior to the time the offering statement is qualified.
Further, please remove
your references to traditional forms of advertising after your
offering statement is
qualified, as TV and radio advertisements are not permitted under
Rule 251(d)(1)(iii),
once your offering statement has been qualified.
Ernest Hemple
FirstName
Hoop StreetLastNameErnest
Center I Corp Hemple
Comapany25,
February NameHoop
2021 Street Center I Corp
February
Page 2 25, 2021 Page 2
FirstName LastName
General
2. We note your response and the revisions to your website in response to
Comment 3.
While you have removed references to Top Golf and specific projected
returns, you
continue to state that "Hoop Street Center is projected to earn as
much or more than the
biggest sport centers." Please remove this language or tell us why it
is appropriate to
mention projected earnings given your limited operating history and
that you have not
generated any revenues to date. We also note that you intend to
include an active
hyperlink to your final offering statement, but have not provided an
active hyperlink to
your preliminary offering statement that is currently filed. In this
regard, we note the
company's obligation to include an active hyperlink to its most
current preliminary
offering statement if the company will be soliciting indications of
interest prior to
qualification pursuant to Rule 255. Finally, please revise the
language in the legend at the
bottom of your landing page to comply with Rules 251(d) and 255 of
Regulation A. The
language in the first paragraph on the top of your cover page could be
added to your
website to meet these requirements.
Please contact Taylor Beech at 202-551-4515 or Katherine Bagley at
202-551-2545 with
any questions.
Sincerely,
Division of
Corporation Finance
Office of Trade
& Services
cc: Adam Wardel, Esq.