SEC – ‘UPLOAD’ from 11/19/18 re: SlideBelts Inc. – ‘TEXT-EXTRACT’

On:  Monday, 11/19/18, at 4:54pm ET   ·   Delayed-Release:  Filing ¶  –  Release Delayed to:  1/30/19   ·   Accession #:  0-18-35770

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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     33K 
 2: TEXT-EXTRACT  Comment or Other Letter from the SEC (PDF Text)      2±    10K 

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

                                                           November 19, 2018

Brig Taylor                                                                     
Chief Executive Officer                                                         
SlideBelts Inc.                                                                 
4818 Golden Foothill Pkwy                                                       
Unit #9, El Dorado Hills, CA 95762                                              

Re: SlideBelts Inc.                                               
Amendment to Offering Statement on Form 1-A               
Filed November 2, 2018                                    
File No. 024-10910                                        

Dear Mr. Taylor:                                                                

   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 October 29,  
2018 letter.                                                                    

Form 1-A/A filed November 2, 2018                                               

Notes to Financial Statements                                                   
Note 9:Recent Accounting Pronouncements, page F-39                              

1.    We note your response to comment 4 and understand that you will adopt ASC 
606 in                                                                          
fiscal 2019. Considering that the applicable literature related to  
direct-response advertising                                                     
     in ASC 340-20 will be superseded upon adoption of ASC 606, please tell us
how you have                                                                    
considered providing additional qualitative disclosures to assist   
investors in assessing the                                                      
     significance of the impact that this standard will have on your financial
statements when                                                                 
   adopted. These qualitative disclosures may include a description of the
effects of the                                                                  
     accounting policies that you expect to apply, if determined, and how they
compare to your                                                                 
 current accounting policies. In addition, to the extent that you have
determined the                                                                  
Brig Taylor                                                                   
SlideBelts Inc.                                                                 
November 19, 2018                                                               
Page 2                                                                          
     quantitative impact that adoption of ASU 2014-09 is expected to have on
your financial                                                                  
statements, please disclose such amounts.                         
      You may contact Raj Rajan at 202-551-3388 or Craig Arakawa, Accounting
Branch                                                                          
Chief at 202-551-3650 if you have questions regarding comments on the financial 
statements and                                                                  
related matters. Please contact Ruairi Regan at 202-551-3269 or Pamela Howell,  
Special                                                                         
Counsel, at 202-551-3357 with any other questions.                              

                                                Sincerely,

FirstName LastNameBrig Taylor                              Division of          
Corporation Finance                                                             
                                                          Office of Beverages,
Apparel and                                                                     
Comapany NameSlideBelts Inc.                                                    
                                            Mining
November 19, 2018 Page 2                                                        
cc:       Andrew Stephenson, Esq.                                               
FirstName LastName                                                              

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘UPLOAD’ Filing		Date		Other Filings
Release Delayed to:		1/30/19		CORRESP,  UPLOAD
Filed on:		11/19/18		UPLOAD
		11/2/18		1-A/A,  CORRESP,  UPLOAD
		10/29/18		UPLOAD
				List all Filings

1 Previous Filing that this Filing References

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

10/17/18  SlideBelts Inc.                   1-A                   18:15M                                    Toppan Merrill/FA