Stark Focus Group, Inc. |
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June 26, 2020
VIA EDGAR AND EMAIL
United States Securities and Exchange Commission
Division of Corporation Finance Office of Trade & Services
100 F Street, N.E.
Washington, DC 20549
Attention: Daniel Morris
Dear Sirs/Mesdames:
Re: Stark Focus Group, Inc. Registration Statement on Form S-1 Filed May 29, 2020 File No. 333-237100 |
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Pursuant to Rule 461 of the Securities Act of 1933, as amended, Stark Focus Group, Inc. (the "Company") hereby requests acceleration of the effective date of its Registration Statement on Form S-1 (File No. 333-237100), as amended (the "Registration Statement"), to 4:00 p.m. Eastern Time, on Tuesday, June 30, 2020 or as soon thereafter as practicable.
The Company hereby acknowledges its responsibilities under the United States Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate to the proposed public offering of the securities specified in the Registration Statement. In addition, the Company acknowledges that:
| · | should the Securities and Exchange Commission (the "Commission") or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission or the staff from taking any action with respect to the filing; |
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| · | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
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| · | the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
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Please contact Jonathan Lotz of Lotz & Company, special counsel to the Company, at (604) 699-0110, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.
Yours truly,
STARK FOCUS GROUP, INC.
Per: | |||
By: | /s/ Mario Todd | ||
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| Mario Todd | |
Chief Executive Officer | |||
cc: Lotz & Company Attention: Jonathan Lotz, ESQ. (via email) |
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