Cassidy & Associates
Attorneys at Law
215 Apolena Avenue
Newport Beach, California 92662
----------
Email: lwcassidy@aol.com
Telephone: 949/673-4510 Fax: 949/673-4525
September 1, 2017
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Amendment No. 1 to
Orchid Grove Acquisition Corporation
File No. 000-55812
Mesdames/Gentlemen:
I attach for filing Amendment No. 1 to the Orchid Grove
Acquisition Corporation registration statement on Form 10-12g.
The following responses address the comments of the reviewing
staff of the Commission as set forth in a comment letter dated
August 3, 2017 (the "Comment Letter"). The comments in the Comment
Letter are sequentially numbered and the answers set forth herein
refer to each of the comments by number and by citing the location
of each response thereto in the Registration Statement.
General
1. The correct name of the Registrant is Orchid Grove Acquisition
Corporation. A typographical error was made when submitting the
the Form ID form for the Edgar CIK number. The correction to
the correct name has been submitted to the EDGAR system and the
correct name should appear on the next filing made to CIK
0001709774.
2. The Staff's comment is noted and the Registrant understands the
filing requirements once the Form 10 becomes automatically
effective.
Risk Factors
3. The risk factor headings have been made more easily identifiable
and distinct. The Registrant is filing the document in ASCII
which format does not provide for bold face or italicized type
of individual headings or paragraphs. The risk factor texts
have been indented to make them more readily apparent.
Terms of a Business Combination
4. The requested disclosure has been added and appears on page 14.
Recent Blank Check Companies
5. The requested disclosure has been added and appears on page 16.
Management notes, however, that it is not informed or copied with
any subpoenas issued by the Securities and Exchange Commission and
only knows of those subpoenas listed because the companies receiving
such subpoenas notified management.
6. The listing of Recent Blank Check Companies beginning on page 20 has
been reviewed and revised to update and ensure its accuracy. Management
is grateful for the assistance provided by the Staff in its review of
this section. Those changes as well as others have been incorporated.
Conflicts of Interest
7. The name Orchid Grove Acquisition Corporation is the correct name as it
appears on the certificate of incorporation and bylaws. The incorrect
name appearing on the Edgar system under that CIK number has been
corrected and the name Orchid Grove Acquisition Corporation should appear
with the next filing on the Edgar using the assigned CIK number.
/s/ Lee Cassidy
Cell phone: 202-415-3563