Feb. 22, 2021
SEC or to Whom it may concern, I am writing today with respect to the proposed amendment to Rule 144. As the CEO of an OTC Public Company, I have experienced the good, the bad and the ugly when it comes to financings, convertibles or even Venture Capital investors, when funding some of our private ventures, all in all, they all have their pluses and minuses in my opinion. This said, we have had some of our biggest successes when having started with convertible note financing, building our business or piloting a service, then racketing up growth to achieve future rounds of financing at more favorable rates, it seems to me that certain aspects of the registered offering (S1 or REG A etc.) offer some of these same features and can often be even more dilutive, but the upside is the fixed price, which I understand is a good trade off. Simply put, having options and opportunity to stay alive when you are attempting to figure out technology, trends, customers and virtually everything that goes along with building a business is the key to succeeding on the OTC. It is certainly a marketplace that is looked upon with a high degree of skepticism at times and along with this come the judgement of how financial partners are willing to fund growth stage company's like ours, it seems only fair that allowing these firms and individuals the flexibility to work with Company's like ours in a way that provides the opportunity for success, along with a substantial upside when or if that success happens, unfortunately there are no guarantees when it comes to timing or market acceptance of a product or service. Our business has found a pivot to the COVID 19 Pandemic and has created a platform that supports music artists that have been left with no ability to perform or earn and our ability to continue building upon the success we are having relies upon our effectiveness of our Regulation A filing, along with our ability to fill the offering and of course, continue providing a viable platform for performing artists. One of the things that is sometimes missed when a party is outside the company, rather than manning the ship…these convertible funding opportunities have allowed us to get to the point of even being able to file a Regulation A offering and continue with our quest of becoming a real solution for touring artists for years to come. I appreciate the opportunity to share my thoughts and would request the commission reconsider the current form of this amendment to Rule 144. Thank you, Robert A. Rositano Jr. Friendable, Inc. Chief Executive Officer Thank you, Robert Rositano Jr. CEO Friendable, Inc.