SEC – ‘UPLOAD’ from 6/7/19 re: Building Bits Properties I, LLC – ‘TEXT-EXTRACT’

On:  Friday, 6/7/19, at 6:08pm ET   ·   Delayed-Release:  Filing ¶  –  Release Delayed to:  7/16/19   ·   Accession #:  0-19-9608

in

this entire Filing. an “Entity” Search.

Show

Documents searched

and

each “hit”. the 1st “hit”.

↓↑Hints

Delayed-Release Comment or Other Letter from the SEC
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: LETTER      Comment or Other Letter from the SEC                 PDF     34K 
 2: TEXT-EXTRACT  Comment or Other Letter from the SEC (PDF Text)      2±    11K 

‘TEXT-EXTRACT’   —   Comment or Other Letter from the SEC (PDF Text)
Document Table of Contents

                                                          June 7, 2019

Alexander Aginsky                                                               
Chief Executive Officer                                                         
Building Bits Properties I, LLC                                                 
425 NW 10th Ave, Suite 306                                                      
Portland, OR 97209                                                              

Re: Building Bits Properties I, LLC                               
Offering Statement on Form 1-A                            
Post-Qualification Amendment No. 2                        
Filed May 24, 2019                                        
File No. 024-10839                                        

Dear Mr. Aginsky:                                                               

      We have reviewed your amendment 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 this letter by amending your offering statement and
providing the                                                                   
requested information. If you do not believe our comments apply to your facts   
and                                                                             
circumstances or do not believe an amendment is appropriate, please tell us why 
in your                                                                         
response. After reviewing any amendment to your offering statement and the      
information you                                                                 
provide in response to these comments, we may have additional comments.         

Form 1-A POS filed May 24, 2019                                                 

Cover Page                                                                      

1.     Please revise the disclosure throughout, including the table on the      
cover page, to specify                                                          
 the minimum offering amounts for each class of security offered. If
there is no minimum                                                             
     for the Common or Preferred Bits, as a standalone class, please provide
clear disclosure of                                                             
this.                                                             
2.     Revise to highlight the different attributes of the Preferred Bits.      
Risk Factors                                                                    
Investors in this offering that purchase Preferred Bits, page 7                 

3.     Please revise to highlight the extent to which the no minimum nature of  
the Common Bit                                                                  
   offering may intensify this risk. In addition, given that there is no
market for the Bits,                                                            
Alexander Aginsky                                                             
Building Bits Properties I, LLC                                                 
June 7, 2019                                                                    
Page 2                                                                          
    emphasize the extent to which Common Bit holders have no exit strategy
other than a                                                                    
liquidation or change in control of the property.                 
Plan of Distribution, page 15                                                   

4.     Please explain how you will allocate shares among Common and Preferred   
subscribers if                                                                  
the offering is oversubscribed.                                   

       We will consider qualifying your offering statement at your request. If
a participant in                                                                
your offering is required to clear its compensation arrangements with FINRA,    
please have                                                                     
FINRA advise us that it has no objections to the compensation arrangements      
prior to                                                                        
qualification.                                                                  

     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.                                                            

Please contact Josh Lobert, Staff Attorney, at 202-551-7150 or Kim
Mcmanus, Senior                                                                 
Attorney, at 202-551-3215 with any questions.                                   

                                                    Sincerely,

FirstName LastNameAlexander Aginsky                          Division of        
Corporation Finance                                                             
                                                        Office of Real
Estate and                                                                      
Comapany NameBuilding Bits Properties I, LLC                                    
                                                     Commodities
June 7, 2019 Page 2                                                             
cc:       Andrew Stephenson                                                     
FirstName LastName                                                              

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘UPLOAD’ Filing		Date		Other Filings
Release Delayed to:		7/16/19		CORRESP,  UPLOAD
Filed on:		6/7/19		UPLOAD
		5/24/19		1-A POS,  CORRESP,  UPLOAD
				List all Filings

1 Previous Filing that this Filing References

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

 5/24/19  Building Bits Properties I, LLC   1-A POS                2:2.1M                                   EdgarAgents LLC/FA