0001493152-17-015102.txt : 20180330 0001493152-17-015102.hdr.sgml : 20180330 20171227154452 ACCESSION NUMBER: 0001493152-17-015102 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20171227 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SACK LUNCH PRODUCTIONS INC. CENTRAL INDEX KEY: 0000833209 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-AMUSEMENT & RECREATION SERVICES [7900] IRS NUMBER: 841062062 STATE OF INCORPORATION: UT FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 59 WEST 100 SOUTH CITY: SALT LAKE CITY STATE: UT ZIP: 84101 BUSINESS PHONE: 8015758073 MAIL ADDRESS: STREET 1: 59 WEST 100 SOUTH CITY: SALT LAKE CITY STATE: UT ZIP: 84101 FORMER COMPANY: FORMER CONFORMED NAME: NEXIA HOLDINGS INC DATE OF NAME CHANGE: 20020401 FORMER COMPANY: FORMER CONFORMED NAME: KELLYS COFFEE GROUP INC DATE OF NAME CHANGE: 19940603 FORMER COMPANY: FORMER CONFORMED NAME: GREAT EARTH VITAMIN GROUP INC DATE OF NAME CHANGE: 19940107 CORRESP 1 filename1.htm

December 27, 2017

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attn:	John Dana Brown

	Re:	Sack Lunch Productions, Inc.
		Amendment No. 2 to
		Offering Statement on Form 1-A
		Filed December 12, 2017
		File No. 024-10726

Dear Mr. Brown:

The following responses of Sack Lunch Productions, Inc. (the “Company,” “we” or “us”) are being provided in response to your comment letter dated December 20, 2017, regarding the above-listed Offering Statement on Form 1-A for the Company. We have summarized the Staff’s comments in bold and italics followed by the Company’s response.

Part II

Offering Circular

Exhibits, page 95

1. We note your response to our prior comment 3 and reissue. Please file the TCA Agreement listed as Exhibit 6.7 in its entirety, including all exhibits and schedules that are identified in the index on page 90 of the agreement. In this regard, we are unable to locate Exhibit A, and Schedules 7.18(b), 7.33, 9.3 and 10.8.

We have re-filed the TCA Agreement in its entirety as Exhibit 6.7 of Amendment No. 3 to the Offering Statement on Form 1-A filed concurrently herewith. We have conducted an exhaustive review of our files and were able to find Exhibit A to the TCA Agreement in another file. However, we have confirmed that Schedules 7.18(b), 7.33, 9.3 and 10.8, though referenced in the TCA Agreement, were not prepared for the TCA Agreement and simply do not exist. The likely explanation is there was nothing to report on these Schedules. Please also note that all of these Exhibits and Schedules are immaterial to the overall agreement.

United States Securities and Exchange Commission

Division of Corporation Finance

December 26, 2017

Page 2 of 2

Signatures

4. We note that your Form 1-A no longer includes the required signatures. Please revise to include the signatures required by Form 1-A.

The signatures were unintentionally omitted. Amendment No. 3 to the Offering Statement on Form 1-A, filed concurrently herewith, includes the required signatures.

Thank you for your time and attention to this matter. Should you have any questions, please contact our counsel, Brian Lebrecht, at (801) 433-2453.

	Very truly yours,

	/s/ Richard Surber
	Richard Surber
	Chief Executive Officer