United States securities and exchange commission logo
January 4, 2023
Erik S. Nelson
Chief Executive Officer
Bellatora, Inc.
2030 Powers Ferry Road SE, Suite #212
Atlanta, GA 30339
Re: Bellatora, Inc.
Amendment No. 2 to
Registration Statement on Form 10-12G
Filed December 22,
2022
File No. 000-56478
Dear Erik S. Nelson:
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. 2 to Registration Statement on Form 10-12G filed December
22, 2022
Item 2. Financial Information
Plan of Operation, page 16
1. Please revise the table
to include actual Q3 operating expense amounts and updated Q4
projected amounts.
Also, in the first sentence following the table, revise the amount of
cash on hand to be
$3,598 as of September 30, 2022.
Results of Operations for the Nine Months Ended September 30, 2022
Compared to the Nine
Months Ended September 30, 2021, page 18
2. Please revise to break
out the material components of the $61,065 in general and
administrative expenses
incurred during the nine months ended September 30, 2022. In
this regard, we note
that general and administrative expenses increased by $52,790 from
the six months ended
June 30, 2022 to the nine months ended September 30, 2022. In
Erik S. Nelson
Bellatora, Inc.
January 4, 2023
Page 2
addition, we note that general and administrative expenses for the year
ended December
31, 2021 were $35,901. Please also revise, as appropriate, to the extent
the increase in
general and administrative expenses is a material event or uncertainty
and to the extent
management believes the increase indicates a trend. Refer to Item 303 of
Regulation S-
K.
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 Robert Telewicz at
202-551-3438 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Benjamin Holt at 202-551-6614 or David Link at 202-551-3356 with any
other
questions.
Sincerely,
FirstName LastNameErik S. Nelson
Division of
Corporation Finance
Comapany NameBellatora, Inc.
Office of Real
Estate & Construction
January 4, 2023 Page 2
cc: Robert J. Mottern, Esq.
FirstName LastName