Strategic Global Investments, Inc. (STBV)

[420man]

I'm at computer finally:

Quote:
Cover Page
1. We note that you are attempting to register a maximum offering amount of $5,000,000.
However, Rule 251 (b) under Regulation A provides for an exemption from registration of up to
a maximum aggregate offering price of $5,000,000 for all securities sold within twelve-month
period. Inasmuch as Item 5 on page 3 of your offering circular indicates that a total of $1,
527,500 has been raised pursuant to Regulation A since March 18, 2013, it appears that you are
not eligible to offer the full $5,000,000. Please revise or advise.
Response: Please be advised that we are aware of the aggregate sales price limitation and did not intent
to exceed it. In our mind, the $5,000,000 amount on the offering circular cover page was
intended to cover the total of all three offerings. However, we can see how this creates
confusion. In response to this Comment and Comment No. 3, we have revised the cover page
and the rest of the offering circular to make clear that we are selling Units consisting of 100
shares of common stock for $0.01 per Unit up to a total of $3,000,000 in proceeds. See "Cover
Page" and other parts of the offering circular which describe the offering in Amendment 1.


http://www.sec.gov/Archives/edgar/data/823187/000000000014007426/filename1.pdf

Oh my..so they tried to sneak in the $5 mill but the SEC caught it and informed them that they can only sell a total of $3.4ish mill that remained for the (March 2013 to March 2014) fiscal year!!?? Can you tell me if that/this means that they could have already started selling more Reg 1-A's sometime in March of this year 2014?