TICKET CORP.
9625 Mission Gorge Road, Suite B2 #318
Santee, CA 92071
e-mail: ticketcorp1@yahoo.com
Telephone (775) 352-3936 Fax (775) 201-8190
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June 3, 2014
Via EDGAR
Mr. John Dana Brown
Ms. Theresa Messinese
United States Securities and Exchange Commission
Washington, D.C. 20549
Re: Ticket Corp.
Amendment No. 5 to Registration Statement on Form S-1
Filed May 7, 2014
File No. 333-187544
Dear Mr. Brown and Ms. Messinese:
In response to your letter of May 21, 2014 regarding the Company's Amended
Registration Statement on Form S-1 filed May 7, 2014 we have further amended the
Registration Statement and provide this cover letter to identify the changes
made.
Description of Our Business, page 18
Principal Products or Services and Their Markets, page 18
1. We have removed the sentence related to the company tracking when new
tickets will be on sale. We have revised the disclosure to read: "The
Company intends to record when new event tickets will be on sale,
physically purchase initial ticket inventories and utilize our
software to allow us to track and analyze ticket pricing trends in
order to purchase tickets as close as possible at their lowest
purchase point. We will continue to buy and sell tickets up to the
time the event occurs."
2. Stubhub only has an agreement with major league baseball to cancel and
reissue new bar codes. Ticketmaster only cancels and reissues new bar
codes for venues they own or shows they manage or support. We have
clarified in our filing the fact that we, as well as Stubhub and
Ticketmaster, are able to forward original ticket Bar codes.
Pricing, page 22
3. We have revised this paragraph in order to clarify the effects of
pricing that follows common economic rules of supply and demand.
We acknowledge and understand that the company and management are responsible
for the accuracy and adequacy of the disclosures made in our filings. The
company further acknowledges that:
* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy and
accuracy of the disclosure in the filing; and
* the company may not assert staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.
Sincerely,
/s/ Russell Rheingrover
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Russell Rheingrover
President & Director
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