Cassidy & Associates
Attorneys at Law
215 Apolena Avenue
Newport Beach, California 92662
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Email: CassidyLaw@aol.com
Telephone: 202/387-5400 Fax: 949/673-4525
August 26, 2013
Russell Mancuso
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Glenwalk Acquisition Corporation
File No. 0-54980
Dear Mr. Mancuso
Attached for filing with the Securities and Exchange
Commission in response to the Commission's letter of
July 18, 2013, is Amendment No. 1 to the Glenwalk Acquisition
Corporation Form 10-12G. The written acknowledgement from the
Company has been filed simultaneously with the amendment and this
letter.
The following response addresses the comment of the reviewing
staff of the Commission as set forth in its comment letter.
Facing Page
1. The noted text was a typographical error.
2. IRS Employer Identification number has been added.
Business
3. The disclosure has been amended and no uncertainty
existed other than to reflect the careful application of a
rule that does not explicity state "automatic" qualification
but begins with "to qualify" as an emerging growth
company.
4. The noted language was added in response to a specific
comment received from a reviewing examiner for an earlier
filing for a similar company in order to additionally
clarify that the public company, Glenwalk, is used as part
of a process of taking a private company public. Indeed
that private company may choose to utilize an existing public
vehicle or may choose to file a registration statement pursuant
to the Securities Act of 1933 and not avail itself of the public
company. In all cases, the private company is engaging Tiber
Creek Corporation to assist it in becoming a public
company. Language has been added for clarification and appears
on page 1 and language has been deleted on page 15.
Jumpstart Our Business Startups Act
5. Disclosure has been added and appears on page 3.
Risk Factors
6. The risk factor regarding voting control by the existing
shareholders has has been added and appears on page 8.
General Business Plan
7. The noted disclosure has been clarified and appears on
page 14.
Undertakings and Understandings Required of Private Companies
8. The disclosure has been revised to more accurately
reflect the understandings of Tiber Creek Corporation
and appears on page 17.
Recent Blank Check Companies
9. Tiber Creek enters into contracts wth various private company
clients for its assistance in making that private company a
public reporting company. Tiber Creek also provides clients
additional services such as assistance in corporate structuring,
introductions to the brokerage community and review of documents
or materials intended to be used by the private company once
a public reporting company. In that regard, like a law firm
with many clients, each client of Tiber Creek is a dinstinct
and separate entity and the billings to each client is
proprietary and confidential. As noted in the Conflicts of
Interest section, the use of the public company, such as
Glenwalk, does not pose a conflict of interest between or
among clients of Tiber Creek as each of the public companies,
such as Glenwalk is a blank check company and has
identical corporate and management structure.
10. The new directors and new management of Hardwood Acquisition
and Lightwood Acquisition are no longer in communication
with the original shareholders and the original shareholders
do not know the status of any additional stock issuances.
Conflicts of Interest
11. The noted disclosure has been revised and appears on page 26.
Signature Page
12. The typographical error has been corrected and the complete
date appears on the signature page.
Sincerely,
/s/ Lee W. Cassidy