Lodging Media, Inc.
Rua Leopoldo Miguez, 159,
Rio de Janeiro, RJ, Brazil, 22060-020
|
Attention:
|
Barbara C. Jacobs
Assistant Director
|
Re:
|
Lodging Media, Inc. ("the Company")
|
|
Amendment No. 1 to Registration Statement on Form S-1
|
||
File No. 333-186482
|
||
Filed March 14, 2013
|
1.
|
Please update your financial statements and related financial information included in the filing, as necessary, to comply with Rule 8-08 of Regulation S-X.
|
2.
|
We note the revisions made in response to prior comment 4. Please revise to clarify that your reporting obligations pursuant to Section 15(d) will be suspended while you have a class of securities registered under Section 12 or, if on the first day of any fiscal year other than the year in which a Securities Act registration statement becomes effective, you have fewer than 300 record holders of the class of securities offered under the Securities Act registration statement. For guidance, see Small Business and the SEC, available on our website at http://www.sec.gov/info/smallbus/qasbsec.htm.
|
3.
|
We note your response to prior comment 7 and are unable to agree with your analysis. Given that you have not yet begun operations and may not provide listings on a global scale for some time, it is unclear why potential conflicts between your executive officers and your company are not material. Please provide further analysis.
|
4.
|
We refer to prior comment 9. You state that you will market your website to property owners "from around the world." Please identify the specific regions in which you intend to provide short term for-rent-by-owner listings.
|
Yours truly,
|
|||
LODGING MEDIA, INC. | |||
|
Per:
|
/s/ Joao Neto | |
Joao Neto, President |