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Wednesday, May 06, 2015 10:26:03 AM
October 20, 2014
Via E-mail
Robert Federowicz
Chief Executive Officer
Aristocrat Group Corp.
495 Grand Boulevard, Suite 206
Miramar Beach, Florida
Re: Aristocrat Group Corp.
Registration Statement on Form S-1
Filed on September 25, 2014
File No. 333-198947
Dear Mr. Federowicz:
We have reviewed your filing solely for the issue noted below, and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. Where you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
Selling Stockholder, page 24
1. We note the representation that no affiliate of Jaxon Group Corp or John Morrissey has served as an officer or director of your Company within the last three years or has had a material relationship with the Company. Please confirm that your former chief executive officer and director, Cindy Morrissey, is not related to Mr. Morrissey nor
otherwise affiliated with the Jaxon Group Corp.
You may contact Paul Fischer, Attorney-Advisor, at (202) 551-3415, or me at (202) 551-3810, with any questions.
Sincerely,
/s/ Terry French for
Larry Spirgel
Assistant Director
John Morrissey is in fact Cindy's nephew (he is the son of Cindy's brother Thomas Morrissey). Nothing new here - typical of Cindy's sister Kathleen to try and hide their ownership in the company.
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