SEC – ‘UPLOAD’ from 3/1/21 re: Piestro, Inc. – ‘TEXT-EXTRACT’

On:  Monday, 3/1/21, at 3:30pm ET   ·   Delayed-Release:  Filing ¶  –  Release Delayed   ·   Accession #:  0-21-2420

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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     29K 
 2: TEXT-EXTRACT  Comment or Other Letter from the SEC - PDF's         2±     9K 
                Text                                                             

‘TEXT-EXTRACT’   —   Comment or Other Letter from the SEC – PDF’s Text

United States securities and exchange commission logo                           

March 1, 2021         

Massimo De Marco                                                  
Chief Executive Officer                                           
Piestro, Inc.                                                     
1134 11th Street, Suite 101                                       
Santa Monica, CA 90403                                            

                                                 Re: Piestro, Inc.
                                                          Amendment No. 3 to
Offering Statement on Form 1-A                                                  
                                                          Filed February 12,
2021                                                                            
                                                          File No. 024-11315

Dear Mr. De Marco:                                                

       We have reviewed your amended offering statement 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.
Unless we note                                                                  
otherwise, our references to prior comments are to comments in our
February 5, 2021 letter.                                                        

  Amendment No. 3 to Offering Statement on Form 1-A filed February 12,
2021                                                                            

General                                                           

1.                                                   We re-issue our prior
comment 6 in part, as you have not updated the hyperlink on the                 
                                                      StartEngine website to
link to your most recently filed offering statement amendment.                  
                                                 Please update the
hyperlink on the StartEngine website so that it hyperlinks to the most          
                                                   recent amendment of
your offering statement. Please also confirm that you will continue             
                                              to update this
hyperlink as you continue to amend your filing. Refer to Rule 255(b)(4)(ii)     
                                             and (d)(2) of
Regulation S-K.                                                                 
2.                                                   We note that your    
profile page on the StartEngine website reflects that you are providing         
                                                     three different tiers
of investor "perks" in connection with this offering.                           
                                              Please include
disclosure about the investor perks in your offering circular, including a      
Massimo De Marco                                                              
Piestro, Inc.                                                                   
March 1, 2021                                                                   
Page 2                                                                          
clear explanation of the different tiers of perks, a definition of  
"Piestro credits," and                                                          
illustrative examples of how the "Piestro credits" may be used by   
reservation holders.                                                            
Further, please clarify whether reservation holders are required to 
complete an investment                                                          
    in your offering prior to receiving any of these perks, considering your
response to                                                                     
   comment 6 indicating that reservations are non-binding. Finally, please
clarify whether                                                                 
     you will be implementing the perks and bonus share programs together, and
whether each                                                                    
program will have any impact on the other.                          
   Please contact Nicholas Lamparski at (202) 551-4695 or Katherine Bagley
at (202) 551-                                                                   
2545 with any questions.                                                        

                                                Sincerely,
FirstName LastNameMassimo De Marco                                              
                                                 Division of
Corporation Finance                                                             
Comapany NamePiestro, Inc.                                                      
                                                       Office of Trade &
Services                                                                        
March 1, 2021 Page 2                                                            
cc:       Andrew Stephenson                                                     
FirstName LastName                                                              

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘UPLOAD’ Filing		Date		Other Filings
Filed on:		3/1/21		UPLOAD
		2/12/21		1-A/A,  CORRESP,  UPLOAD
		2/5/21		UPLOAD
				List all Filings