United States securities and exchange commission logo
June 6, 2022
Steven Mitcham
President
Diligent Capital Holdings, Inc.
302 Perimeter Center N
Atlanta, Georgia, 30346
Re: Diligent Capital
Holdings, Inc.
Registration
Statement on Form 10-12G
Filed May 11, 2022
File No. 000-56439
Dear Mr. Mitcham:
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.
Registration Statement on Form 10-12G Filed May 11, 2022
Item 4. Security Ownership of Certain Beneficial Owners and Management,
page 15
1. Since Messrs. Mitcham
and Carvan are the beneficial owners of SX Capital Management
LLC, please include the
entire 1 million shares of common stock held by SX Capital in the
beneficial ownership
for each of the beneficial owners.
Item 5. Directors and Executive Officers, page 16
2. Please describe the
business experience during the past five years of Messrs. Mitcham and
Carvan including their
principal occupations and employment during the past five years
and the name and
principal business of any corporation or other organization in which the
occupations and
employment were carried on. See Item 5 of Form 10 and Item 401(e) of
Regulation S-K.
Steven Mitcham
Diligent Capital Holdings, Inc.
June 6, 2022
Page 2
Exhibits
3. We note that the certificate of incorporation attached as an exhibit
is for BSX Energy
Holdings, Inc. Please file the correct certificate or advise. Please
also ensure that the
disclosure in the Form 10 is consistent with the information included
in the certificate,
including the number of shares authorized and the authorization of
preferred stock.
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 Frank Knapp at 202-551-3805 or Shannon Menjivar at
202-551-3856 if
you have questions regarding the financial statements and related matters.
Please contact Ronald
(Ron) E. Alper at 202-551-3329 or Pam Howell at 202-551-3357 with any other
questions.
FirstName LastNameSteven Mitcham Sincerely,
Comapany NameDiligent Capital Holdings, Inc.
Division of
Corporation Finance
June 6, 2022 Page 2 Office of Real
Estate & Construction
FirstName LastName