0001004878-14-000186.txt : 20150304 0001004878-14-000186.hdr.sgml : 20150304 20140512195717 ACCESSION NUMBER: 0001004878-14-000186 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20140512 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Advanced Cannabis Solutions, Inc. CENTRAL INDEX KEY: 0001477009 STANDARD INDUSTRIAL CLASSIFICATION: OIL, GAS FIELD SERVICES, NBC [1389] IRS NUMBER: 208096131 STATE OF INCORPORATION: CO FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6565 EAST EVANS AVENUE CITY: DENVER STATE: CO ZIP: 80224 BUSINESS PHONE: (719) 748-5603 MAIL ADDRESS: STREET 1: 6565 EAST EVANS AVENUE CITY: DENVER STATE: CO ZIP: 80224 FORMER COMPANY: FORMER CONFORMED NAME: Promap Corp DATE OF NAME CHANGE: 20091117 CORRESP 1 filename1.txt HART & HART, LLC ATTORNEYS AT LAW 1624 Washington Street Denver, CO 80203 William T. Hart, P.C. ________ Email: harttrinen@aol.com Will Hart Facsimile: (303) 839-5414 (303) 839-0061 May 12, 2014 Angie Kim Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Advanced Cannabis Solutions, Inc. Registration Statement on Form S-1 Amendment No. 1 File No. 333-193890 This office represents Advanced Cannabis Solutions, Inc. (the "Company"). Amendment No. 1 to the Company's registration statement on Form S-1 has been filed with the Commission. This letter provides the Company's responses to the comments received from the staff by letter dated March 10, 2014. The paragraph numbers in this letter correspond with the numbered paragraphs in the staff's comment letter. The number under the "page number" column indicates the page number in the Registration Statement where the response to the comment can be found. A number preceded with the letter "F" indicates the page number of the financial statements where the response to the comment can be found. Page Number 1. The disclosure which is the subject of this comment has been removed. 15 2. The disclosure required by Item 102 of Regulation S-K is included in the "Business" section of the prospectus. Item 509 of Regulation S-K is not applicable to this registration statement. 11, 12 3. The disclosures which are the subject of this comment have been revised. The requested source material is enclosed. 12 4. Comment complied with. 5 5. The amendment to the Company's registration statement has new financial statements. The new financial statements do not reflect any revenue. F-1 6. The disclosure which is the subject of this comment has been expanded. The Company confirms that it has received $500,000 in cash for the warrants sold to Full Circle. 9 Page Number 7. The disclosure which is the subject of this comment has been expanded. 12 8. Comment complied with. 13-14 9. The requested restrictions and guidelines have been added. The Company is a real estate company and does not engage in any activities which are prohibited by federal law. As a result, all tax challenges which may be faced by marijuana growers and dispensaries will not pertain to the Company. 14 10. Comment complied with. 16-17 11. Comment complied with. 18 12. The financial statements have been updated. F-1 13. Counsel is not named in the registration statement and as a result is not required to consent to being named. N/A 14. Comment complied with. Exhibit 5 If you should have any questions concerning the foregoing, please do not hesitate to contact the undersigned. Very Truly Yours, HART & HART, LLC /s/ William T. Hart William T. Hart WTH:ls