Michael A. Littman
Attorney at Law
PO Box 1839
Arvada, CO 80001
(720) 530-6184
malattyco@aol.com
February 22, 2018
United States Securities & Exchange Commission
Division of Corporation Finance
Office of Telecommunications
Attn: Gregory Dundas and Kathleen Krebs
Washington, D.C 20549
Re: TPT Global Tech, Inc.
Registration Statement on Form S-1
Filed December 15, 2017
File No. 333-222094
Dear Mr. Dundas and Ms. Krebs:
Prospectus Cover Page, page 1
1. We note your disclosure that your common stock has traded on the OTC Pink Sheets and that the selling shareholders will be selling at market prices or at any price in privately negotiated transactions. We do not consider the OTC Pink Sheets to constitute a sufficient existing market for selling shareholders to offer their shares at market prices. Therefore, please revise your disclosure to provide a fixed price at which the
selling shareholders will sell their shares for the duration of the offering.
Answer: In response to your comment, TPT Global Tech, Inc. has amended its language to reflect a fixed price for resale until it becomes quoted on the OTCQB which we believe satisfies the requirement of a “sufficient existing market.” OTCQB has approved the application of TPT, in principal, subject to the registration of shares sufficient to constitute 10% of the outstanding in the public float,
Our Company, page 3
2. We note that you have included Blue Collar Inc. and Hollywood Riviera Studio as active subsidiaries of the company in the chart on page 5 and have drafted your business and other disclosure as though the acquisitions have been consummated. As those acquisitions have not been consummated, please delete them from the chart and from the description of your business throughout the registration statement. Instead, disclose the material terms of the acquisition agreements. Highlight the contingent nature of the acquisitions, and discuss how you intend to meet the conditions. Briefly disclose each company’s business and how you intend to integrate the operations into your current business. If you also have not closed the acquisition of Matrixsites, Inc., revise your
disclosure consistent with this comment as well.
Answer: In response to your comment, both Blue Collar and Hollywood Riviera Studios were acquired in the 4th Quarter and these were disclosed in the footnotes to the financial statements for the nine months ended September 30, 2017. (Footnote #10). We are filing an amendment to the HRS and Blue Collar Agreements as Exhibits 10.15 and 10.16 as well as copies of certain promissory notes executed in completion of the
1 |
transactions and it is the opinion of the Company and both parties that all closing requirements have been met for 4th quarter acquisitions. We have also confirmed that the sellers deem the transactions to be completed.
Risk Factors:
Our substantial indebtedness and our current default status .. ., page 7
3. Please revise to quantify the amount of your current indebtedness and the percentage of your indebtedness that is currently in default.
Answer: In response to your comment, we have revised the disclosure at page 8 to add text and disclosure.
Demand for our service offerings may decrease . . . , page 11
4. Please revise to discuss the potential impact on the company of the recent regulatory changes by the FCC with respect to net neutrality.
Answer: In response to your comment, we have added substantial text at page 12, to cover “net neutrality” and other issues.
We will be unable to fully implement our Business Plan . . .. , page 11
5. Please revise to clarify your expected need to raise additional funding in order to fully implement your business plan. We note that you state here that you "will" need to raise additional funds, while in the risk factor on page 16 you state that you "may" require "substantial additional capital" in order to successfully implement your business plan. Please reconcile these two risk factors and disclose the amount and expected timing of your need for funding.
Answer: In response to your comment, in “Risk Factors” we have deleted the text at page 12 and expanded text on page 21 to be congruent and reconcile language.
Selling Security Holders, page 21
6. We note that you have included in your list of selling security holders the shareholders of Hollywood Riviera and Blue Collar Productions. As the acquisitions of Hollywood Riviera and Blue Collar Productions have not closed, tell us why they hold shares in the company and are listed as selling shareholders. Similarly, if the Matrixsites acquisition has not closed, tell us why the owner of Matrixsites holds company shares and is listed as a selling shareholder.
Answer: In response to your comment, the Blue Collar and HRS transactions have closed in the 4th Quarter. Only certain assets of Matrix were acquired for shares, and the transaction closed in the 4th Quarter. Further, see response # 2 above as to Blue Collar and HRS, as to completion of the subject transactions.
7. We note the table on page 21 that lists the transactions through which the selling shareholders obtained their shares. In your response letter, please tell us when each shareholder received their shares, in what transaction, and whether the shares being registered are currently outstanding and held by the selling shareholder.
Answer: In response to your comment, please see attachment at the end of this letter.
8. We note that you list Cede & Co. as a selling shareholder of 3,140,245 shares. Cede & Co. is the nominee name for The Depository Trust Company, a depositary that holds shares of record for banks, brokers and institutions. Therefore, delete Cede & Co. from your table, and instead identify the selling shareholders that hold their securities through Cede & Co.
2 |
Answer: In response to your comment, we have deleted the shares held in Cede & Co. in the list of shares and have adjusted the totals to be registered throughout.
Series B Convertible Preferred Stock, page 29
9. Please disclose the number of shares of Series B Convertible Preferred Stock that are outstanding.
In response to your comment, we have added disclosure of the Series B Convertible Preferred Stock at page 34.
Description of Business, page 30
10. Please revise this section throughout to more clearly describe the company's current business activities and strategic plans. In your discussion, be sure to clearly distinguish between current operations and those parts of your business that are currently aspirational. For example, you state on pages 30 and 31 that the majority of your revenues have been generated from your business as a CLEC in Arizona, that your primary revenues are from telecommunication services and products, and that historically your operating divisions have been those that sell telecommunications services and products. Clarify whether those legacy activities relate to your end goals, and if so, how. When discussing your strategic plans, clarify how you intend to reach your goals, and
explain how the various elements of your business plan and the divisions of your business contribute to those goals. Disclose the expected timing and expenditures to complete these plans.
Answer: In response to your comment, we have substantially edited the text at pages 37 to 40 to amplify the discussion to address the issues listed in the last three sentences of the comment.
Our Business Segments, page 35
11. You state on page 35 that you will describe your key products and services in greater detail, but that description does not appear to be forthcoming. Please revise to provide this disclosure.
Answer: In response to your comment, we have added the disclosure at page __ for the key products and services.
Our Capital Budget for the next 12 months, page 46
12. In your chart, please clarify what the heading "Telco" refers to, such as whether it refers to Copperhead or something else.
Answer: In response to your comment, we have edited the text at page 39 and better disclosed it as a “Proposed Acquisition.”
Liquidity and Capital Resources, page 56
13. Provide a full discussion of your liquidity and capital resources needs for the next 12 months or longer, in order to complete your business plans. We note specifically in this regard your disclosure on page 46 of your capital budget for the next 12 months, your disclosure on page F-27 that several planned acquisitions are pending securing financing and may not occur," and the risk factor discussion on page 7 regarding your "substantial indebtedness" some of which is currently in default.
Answer: In response to your comment, we have added disclosure at page 68 where marked as (“Comment #13”).
3 |
Directors and Executive Officers, page 60
14. Please revise the discussions of your management's business experience to provide clear disclosure regarding the activities of each officer or director during the last five years.
Answer: In response to your comment, we have edited the discussion to disclose the activity history of Officers and Directors at pages 72, 73 where noted (“Comment #14”).
Compensation, page 63
15. Please update your executive compensation disclosure for fiscal year 2017.
In response to your comment, we have edited the Compensation Disclosure at page 76 where noted as (“Comment #15”).
Signatures, page 78
16. Please revise to include the signature of the Controller or Principal Accounting Officer.
Answer: In response to your comment, Mr. Cook signs as Principal Accounting Officer.
Financial Statements
Note 1 - Description of Business and Summary of Significant Accounting Policies, page F-10
17. Refer to your accounting policy for revenue recognition on page F-10. We note on page 11 that you use third party sales organizations and that you have limited control over their operations. Please expand your accounting policy to explain the timing for revenues generated through the use of third party sales organizations.
Answer: In response to your comment, we have eliminated this risk factor. We do not feel that change to the footnote disclosure is appropriate and no longer feel that this is a significant risk. There is no difference in revenue recognition whether products and services are sold by third parties or sold internally.
18. Refer to your discussion of business segments on page 35. Please expand your accounting policies to describe the basis for your belief that the CLEC operations and the ViVoware operations should be presented as a single segment.
Answer: In response to your comment, ViVoware was taken out of the document. It is not a product that will be used for resale, nor is there any difference in its use regarding revenue recognition.
Exhibit 5.1
19. Refer to the second and third paragraphs of counsel’s opinion. We note the list of three documents counsel reviewed and counsel’s statement that he limited his examination to only those documents. We also note counsel’s statement that he did not undertake “to verify the adequacy or accuracy of such documents and records.” These statements inappropriately qualify and limit the scope of counsel’s opinion. Please have counsel revise his opinion
- to clarify that he has examined all other documents he deems necessary to form his opinions and has not limited his examination to only the three documents listed, and
- to remove any indication that he has not verified the adequacy of such documents in reaching his conclusion on the legality of the shares being offered.
4 |
For guidance, refer to CF Staff Legal Bulletin No. 19.
Answer: In response to your comment, please see the revisions to the letter where marked (“Comment #19”).
20. Refer to the fourth paragraph of counsel’s opinion. We note that counsel states that the stock being registered “is and will be” duly and validity authorized, etc. The use of “will be” suggests that some of the shares are not currently outstanding. If so, please have counsel clarify what shares are not currently outstanding.
Answer: In response to this comment, language has been revised in the opinion. Please see area marked (“Comment #20”).
We hope these amendments meet your satisfaction.
Sincerely,
/s/ Michael A. Littman
Michael A. Littman
5 |
TPT Global Tech, Inc. | |||
Selling Shareholders | |||
(Comment #7) | |||
Currently Held | |||
And Being | |||
Registered | |||
Shareholder | Transaction Received Shares | Price/Share | Shares |
ANDY NEAL | Stock Purchase | .10 to .50 | 180 |
ARTHUR BRANDING | Stock Purchase | .10 to .50 | 1,000 |
BERNIE KARNS | Stock Purchase | .10 to .50 | 12,500 |
Bertram E. Cutler | Ally Pharma Preexisting | 0.001 | 19 |
BREANNE ROJESKI | Stock Purchase | .10 to .50 | 200 |
CAROLS ADAMICK MENDOZA | Stock Purchase | .10 to .50 | 100,000 |
CASH CUTLER | Alley Pharma Preexisting | 0.001 | 4 |
CHRISTOPHER WILLIAMS | Stock Purchase | .10 to .50 | 5,200 |
DALE FINCK | Stock Purchase | .10 to .50 | 1,000 |
DANIEL WROBLESKI | Stock Purchase | .10 to .50 | 800 |
FREDERICK EBERHARDT | Stock Purchase | .10 to .50 | 615,000 |
GUADALUPE SILVA | Stock Purchase | .10 to .50 | 9,350 |
HAYDEN F. BELLAMY | Stock Purchase | .10 to .50 | 10,000 |
J WINSTON MICHAEL TRAVIS OLSON | Stock Purchase | .10 to .50 | 1,000 |
JAMES D. AND KAREN G. SCHINDLER JTWROS | Stock Purchase | .10 to .50 | 1,000 |
JEFF OLSEN | Stock Purchase | .10 to .50 | 339,166 |
JOHN BENDLE | Stock Purchase | .10 to .50 | 2,000 |
KATHI OLSON | Stock Purchase | .10 to .50 | 10,000 |
KRISTEN REDETTE OLSON | Stock Purchase | .10 to .50 | 1,000 |
LOUIS ELLIOTT | Stock Purchase | .10 to .50 | 1,000 |
MARISOL SCHLEMMER | Stock Purchase | .10 to .50 | 21,000 |
MICHAEL EMMERS | Stock Purchase | .10 to .50 | 135,000 |
ROBERT A PUTT | Stock Purchase | .10 to .50 | 2,000 |
ROBERT ANDREWS | Stock Purchase | .10 to .50 | 1,000 |
SHERRY ORSBORN | Stock Purchase | .10 to .50 | 7,500 |
SUSAN ELLSWORTH | Stock Purchase | .10 to .50 | 400 |
SUSAN ROLL REVOCABLE TRUST | Stock Purchase | .10 to .50 | 500,000 |
THOMAS B. SEITER | Stock Purchase | .10 to .50 | 1,000 |
TONI GIGLIOTTI | Stock Purchase | .10 to .50 | 200 |
BRIAN POWERS | Stock Purchase | .10 to .50 | 500,000 |
KN SOLOMON MBAGWU | Stock Purchase | .10 to .50 | 2,000,000 |
EDDIE BAKER | Ally Pharma Preexisting | 0.001 | 4 |
JUAN C. FERNANDEZ | Ally Pharma Preexisting | 0.001 | 12,500 |
KHALID S. DAOUD | Ally Pharma Preexisting | 0.001 | 5,000 |
KOKI NAGASHIMA | Ally Pharma Preexisting | 0.001 | 18,544 |
LUI CHI HO RONALD | Ally Pharma Preexisting | 0.001 | 174 |
MANUEL FERNANDEZ | Ally Pharma Preexisting | 0.001 | 550 |
Shinichro Goto | Ally Pharma Preexisting | 0.001 | 6 |
MATTHEW MCCRIMMON | Ally Pharma Preexisting | 0.001 | 715,000 |
6 |
PRAISE DIRECT HOLDINGS LIMITED | Ally Pharma Preexisting | 0.001 | 1,000 |
SHEN TIAOJUAN | Ally Pharma Preexisting | 0.001 | 200 |
Thomas Mccrimmon IV | Ally Pharma Preexisting | 0.001 | 0 |
ARLENA FARINAS | Ally Pharma Preexisting | 0.001 | 300 |
CHIUWAI SITU | Ally Pharma Preexisting | 0.001 | 400 |
DAVID PINTO | Ally Pharma Preexisting | 0.001 | 200 |
FRANCES MCCRIMMON | Ally Pharma Preexisting | 0.001 | 2,000,000 |
Scott Thomas | Ally Pharma Preexisting | 0.001 | 4 |
MARK ROWAN | Blue collar Acquisition | 0.199 | 2,000,000 |
TODD WIGINGTON | Acquistion Shares | 0.001 | 16,492 |
RICHARD EBERHARDT | Compensation | 0.011 | 2,000,000 |
GARY COOK | Compensation | .25 to .26 | 2,000,000 |
RUSSELL WILLIAMS | Founder Shares | 0.001 | 2,000,000 |
STACIE STRICKER | Compensation | 0.29 | 500,000 |
STEPHEN J THOMAS III | Founder Shares | 0.001 | 2,000,000 |
SCOTT GOODWIN | Goodwin Acquisition Shares | 0.81 | 50,000 |
ERIK VERDUZCO | Hrs Acquisition | 0.199 | 75,954 |
GABRIEL BARBARENA | Hrs Acquisition | 0.199 | 75,954 |
KAROL AND FAYAD PALOS | Hrs Acquisition | 0.199 | 151,907 |
Sue Berry | HRS Acquisition | 0.199 | 50,000 |
Louie Saenz | HRS Acquisition | 0.199 | 75,954 |
Chad Eumura | HRS Acquisition | 0.199 | 50,000 |
MARIA DOLORES NICHOLS | HRS Acquisition | 0.199 | 151,907 |
MIGUEL MEDINA | HRS Acquisition | 0.199 | 151,907 |
OFELIA DE LA TORRE | HRS Acquisition | 0.199 | 197,480 |
PAUL JULIEN | HRS Acquisition | 0.199 | 75,954 |
RAMSES ACOSTA | HRS Acquisition | 0.199 | 151,907 |
ROLANDO NICHOLS | HRS Acquisition | 0.199 | 1,729,224 |
Jamie Hernandez | HRS Acquisition | 0.199 | 100,000 |
LINDA KELLY | Lion Acquisition | 0.26 | 1,000,000 |
QUYNTWAN HENRY | Lion Acquisition | 0.26 | 100,000 |
DUANE JACKSON | Lion Acquistion | 0.26 | 500,000 |
ENOCH BRANDE | Lion Acquistion | 0.26 | 500,000 |
CANE INDUSTRIES LLC | Marketing Services | 0.29 | 50,000 |
PENNY PROS LLC | Marketing Services | 0.29 | 50,000 |
SEO STRADEGY GROUP | Marketing Services | 0.77 | 450,000 |
JOYCE EARLY | Ricks Family Gift | 0.001 | 5,000 |
NATALIE WASHCO | Ricks Family Gift | 0.001 | 5,000 |
BRIAN KENT | San Diego Media Acquisition | 0.59 | 265,950 |
KAREN KENT | San Diego Media Acquisition | 0.59 | 243,225 |
MARIO PENA | Consulting services | 0.001 | 750,000 |
CARLOS ANDRES CASTRO | Stephen Family Gift | 0.001 | 5,000 |
CONRAD CALDERON | Stephen Family Gift | 0.001 | 10,000 |
DELIA DEOQUINO | Stephen Family Gift | 0.001 | 10,000 |
LIZETTE CALDERON | Stephen Family Gift | 0.001 | 150,000 |
SHARON DARRAH | Rick Family Member | 0.001 | 20,000 |
ANDY DOUGHTY | TPT Group Exchange (2) | 0.001 | 60,000 |
BRUNO BARBARAI | TPT Group Exchange (2) | 0.001 | 50,000 |
7 |
CARLETON GREGORY SOLLOWAY | TPT Group Exchange (2) | 0.001 | 250,000 |
CAROL JOANNE BOOTH | TPT Group Exchange (2) | 0.001 | 100,000 |
CECIL JONES | TPT Group Exchange (2) | 0.001 | 32,000 |
CELESTE JANET FITZPATRICK | TPT Group Exchange (2) | 0.001 | 21,000 |
CRAIG FULLER | Compensation | 0.29 | 150,000 |
CRAIG HILL | TPT Group Exchange (2) | 0.001 | 100,000 |
DAVID WARD | TPT Group Exchange (2) | 0.001 | 75,000 |
DEBORAH MILLER | TPT Group Exchange (2) | 0.001 | 2,000 |
DENNI GRIFFITH | TPT Group Exchange (2) | 0.001 | 5,000 |
EMILIANO BONANNO | TPT Group Exchange (2) | 0.001 | 155,000 |
FEIVEL INVESTMENT LLC | TPT Group Exchange (2) | 0.001 | 30,000 |
GARY STEWART | TPT Group Exchange (2) | 0.001 | 20,000 |
GRANT HENRY | TPT Group Exchange (2) | 0.001 | 10,000 |
HOLLY MEAD | TPT Group Exchange (2) | 0.001 | 55,000 |
JEBB DYKSRA | TPT Group Exchange (2) | 0.001 | 75,000 |
JOE OBEZO | TPT Group Exchange (2) | 0.001 | 5,000 |
KONSTANTIN SHAPOVALOV | TPT Group Exchange (2) | 0.001 | 10,000 |
KRISSY BARLOW TAYLOR | TPT Group Exchange (2) | 0.001 | 50,000 |
LAURIE L POWER | TPT Group Exchange (2) | 0.001 | 10,000 |
MARIO SCADE GARCIA | TPT Group Exchange (2) | 0.001 | 25,000 |
MARLA ELLERMAN | TPT Group Exchange (2) | 0.29 | 50,000 |
NORMAN BRANDER | TPT Group Exchange (2) | 0.001 | 5 |
PANTHEON PARTNERS | TPT Group Exchange (2) | 0.001 | 200,000 |
PATRICK TAYLOR | TPT Group Exchange (2) | 0.001 | 10,000 |
REGGIE THOMAS | TPT Group Exchange (2) | 0.001 | 165,000 |
Charles Gregory Thomas | TPT Group Exchange (2) | 0.001 | 8 |
Charles R. Thomas | TPT Group Exchange (2) | 0.001 | 6 |
Wie Family Trust | TPT Group Exchange (2) | 0.001 | 5 |
RIGO FLORES | TPT Group Exchange (2) | 0.001 | 10,000 |
ROBERT GOOLD | TPT Group Exchange (2) | 0.001 | 100,000 |
RUDOLF EDUARD BOHLI | TPT Group Exchange (2) | 0.001 | 500,000 |
SANFORD LEAVENWORTH | TPT Group Exchange (2) | 0.001 | 8,000 |
Shigetomi Komatsu | TPT Group Exchange (2) | 0.001 | 9 |
SHANNON JOHNSON | TPT Group Exchange (2) | 0.001 | 350,000 |
STEPHANIE KRAUSE | TPT Group Exchange (2) | 0.001 | 88,000 |
THOMAS J. POWERS | TPT Group Exchange (2) | 0.001 | 12,000 |
TOM SHAEFFER | TPT Group Exchange (2) | 0.001 | 300,000 |
WARREN WINFIELD GIBSON III | TPT Group Exchange (2) | 0.001 | 100,000 |
YU CHUNG CHO | TPT Group Exchange (2) | 0.001 | 500,000 |
BRIAN MICHAEL FIELDING | CDH Acquisition (1) | 0.01 | 15,035 |
ANDY ELLISON | Trucom Employment | 0.29 | 100,000 |
SHELLY FULTON | Trucom Employment | 0.29 | 250,000 |
BRADEN SCHUSTER | Trucom Employment | 0.29 | 100,000 |
AARON D CLARK | CDH Acquisition (1) | 0.01 | 282,459 |
BENJAMIN AMMONS | CDH Acquisition (1) | 0.01 | 8,764 |
BROWN LIVING TRUST | CDH Acquisition (1) | 0.01 | 16,492 |
CAPITAL-PLUS PARTNERS | CDH Acquisition (1) | 0.01 | 333,422 |
CHRISTIAN A. MASSETTI | CDH Acquisition (1) | 0.01 | 32,500 |
8 |
CHRISTOPHER J. GAVIGAN | CDH Acquisition (1) | 0.01 | 20,330 |
CHRISTOPHER SHIPPY G CANTON | CDH Acquisition (1) | 0.01 | 65,967 |
CINDY ARMSTRONG | Trucom Employment | 0.29 | 125,000 |
CLEAR VIEW COMMUNICATIONS | Debt Exchange | 0.29 | 40,000 |
CONEXUS TELECOM | Debt Exchange | 0.29 | 125,000 |
CRITICAL SYSTEMS & SUPPORT LTD | CDH Acquisition (1) | 0.01 | 13,476 |
DAVID CLARK | CDH Acquisition (1) | 0.01 | 8,246 |
DON & BRENDA MORRIS JT TEN | CDH Acquisition (1) | 0.01 | 3,298 |
DOUGLAS R PETERLIN | CDH Acquisition (1) | 0.01 | 9,616 |
EDWARD DAVIS | CDH Acquisition (1) | 0.01 | 30,000 |
EQUITY TRUST COMPANY, CUSTODIAN FBO KARL M CRISS IRA | CDH Acquisition (1) | 0.01 | 4,383 |
FORESIGHT GROUP LLC | Debt Exchange | 0.29 | 150,000 |
FRED T DAVIS, JR. | CDH Acquisition (1) | 0.01 | 20,000 |
GARY AND JAMIE GORDON JT | CDH Acquisition (1) | 0.01 | 7,499 |
GAYLE SETZER | CDH Acquisition (1) | 0.01 | 50,025 |
GRANT EVANS | CDH Acquisition (1) | 0.01 | 3,298 |
GREG DREW | CDH Acquisition (1) | 0.01 | 3,298 |
GREGG MASSETTI | CDH Acquisition (1) | 0.01 | 10,231 |
HAL CLARK | CDH Acquisition (1) | 0.01 | 21,116 |
IRA HUGHES | CDH Acquisition (1) | 0.01 | 16,492 |
JASON DUNCAN | CDH Acquisition (1) | 0.01 | 16,492 |
JIM RICHARDS | CDH Acquisition (1) | 0.01 | 14,500 |
JOELLE CLARK | CDH Acquisition (1) | 0.01 | 167,541 |
JOHN DREW | CDH Acquisition (1) | 0.01 | 111,649 |
JOHN P. WARD | CDH Acquisition (1) | 0.01 | 36,803 |
JOSEPH LAWRENCE HAGER | CDH Acquisition (1) | 0.01 | 20,330 |
JOSH HITT | CDH Acquisition (1) | 0.01 | 9,525 |
KIM KELLAR | CDH Acquisition (1) | 0.01 | 4,123 |
LISA & DOUG COOPER JT | CDH Acquisition (1) | 0.01 | 10,956 |
M-Cube Corporation | Ally Pharma Preexisting | 0.001 | 6 |
MARK CLARK | CDH Acquisition (1) | 0.01 | 3,298 |
MARK MONTANO | Trucom Employment | 0.29 | 251,649 |
MARK PALUSO | Debt Exchange | 0.29 | 100,000 |
MICHAEL FLEMING | CDH Acquisition (1) | 0.01 | 181,953 |
MICHAEL P MURPHY | CDH Acquisition (1) | 0.01 | 1,541,949 |
NICK MULHOLLAND | Debt Exchange | 0.29 | 75,000 |
NICOLE & ERIC CARTER JT TEN | CDH Acquisition (1) | 0.01 | 3,298 |
PAUL E. KNAG | CDH Acquisition (1) | 0.01 | 15,035 |
PLANET ONE COMMUNICATIONS INC. | Debt Exchange | 0.29 | 150,000 |
ROBERT RICCI | CDH Acquisition (1) | 0.01 | 11,108 |
ROBERT SCHUSTER | Trucom Employment | 0.29 | 100,000 |
ROBERT SETZER | CDH Acquisition (1) | 0.01 | 126,120 |
RON A. LEVENE | CDH Acquisition (1) | 0.01 | 82,767 |
TERRY BRODKIN | CDH Acquisition (1) | 0.01 | 110,000 |
THE MANGIA FAMILY TRUST U/A DTD 01/12/16 | CDH Acquisition (1) | 0.01 | 3,298 |
TRAVIS CLARK | CDH Acquisition (1) | 0.01 | 4,123 |
STEVE CAUDLE | Viewme Live Acquisition Shares | 0.1489 | 2,000,000 |
CHRIS COPELAND | Unknown | 0.001 | 12,675 |
9 |
DAVID I NEWMAN REVOCABLE LIVING TRUST | Unknown | 0.001 | 1,000,000 |
INVESTMENT REAL ESTATE | Unknown | 0.001 | 2,500 |
KERRY J. NEAL | Unknown | 0.001 | 5,000 |
MITSUNOBU AMAZAKI | Unknown | 0.001 | 6 |
PATRICK GUIANT | Unknown | 0.001 | 55,200 |
ROB JENKS | Unknown | 0.001 | 38,025 |
ROBERT JAMES SHUBERT | Unknown | 0.001 | 2,500 |
RON MONARK | Unknown | 0.001 | 125,400 |
Edward Willis Levert Jr. | Unknown | 0.001 | 250,000 |
XROADS LLC | Unknown | 0.001 | 10,000 |
36,953,025 | |||
(1) CDH Acquisition consists of an exchange for the shares of Copperhead Digital. | |||
(2) TPT Group Exchange consists of a distribution in dissolution of the assets of TPT Group LLC. |
10 |