United States securities and exchange commission logo
July 20, 2023
Rasmus Refer
Chief Executive Officer
Trustfeed Corp.
140 Broadway, 46th Floor
New York, NY 10005
Re: Trustfeed Corp.
Amendment No. 1 to
Registration Statement on Form 10-12G
Filed July 6, 2023
File No. 000-56555
Dear Rasmus Refer:
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 to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
June 27, 2023 letter.
Amendment No. 1 to Registration Statement on Form 10-12G filed on July
6, 2023
Products and Services, page 3
1. We note your response
to prior comment 3 and also note your revised disclosure on pages
F-7 and F-15,
indicating that the company generates revenue from customized data
packages, which is a
Leads Ordering system for the purpose of generating lists of sales
leads. Please revise to
ensure that the information in your "Products and Services" section
on page 3 is consistent
with your disclosures on page F-7 and F-15, and your "Revenue
Models" section on page
5.
Rasmus Refer
FirstName LastNameRasmus Refer
Trustfeed Corp.
Comapany
July NameTrustfeed Corp.
20, 2023
July 20,
Page 2 2023 Page 2
FirstName LastName
Business
Competition, page 6
2. We note your response to prior comment 5, including your statement
that your offer
similar services to several leading companies "but with a much larger
platform." To the
extent you continue to include this disclosure, please provide support
for this and other
similar statements and ensure you provide balanced disclosure. For
example, to the extent
that you compare the size of your company platform to the platforms of
leading
competitors, please support your claims by providing numerical
information for each
competitor along with the source of the information relied upon.
Additionally, to balance
this disclosure, please ensure you discuss that these other companies
have much higher
revenue and user counts, among other metrics, than you.
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 Claire DeLabar, Senior Staff Accountant, at
202-551-3349 or Robert
Littlepage, Accounting Branch Chief, at 202-551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact Mariam
Mansaray,
Staff Attorney, at 202-551-6356 or Mitchell Austin, Staff Attorney, at
202-551-3574 with any
other questions.
Sincerely,
Division of
Corporation Finance
Office of
Technology
cc: Scott Doney