Ozop Energy Solutions Inc (OZSC)

[Magnum7419]

"Dear Mr. Conway:

We have limited our review of your filing to the financial statements and relateddisclosures and have the following comments. In some of our comments, we may ask you toprovide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requestedinformation or advise us as soon as possible when you will respond. If you do not believe ourcomments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments.Form 10-Q for Quarterly Period Ended September 30, 2020Note 3 - Summary of Significant Accounting PronouncementsGoodwill, page 101.We note goodwill of $11.4 million recorded on your balance sheet at September 30, 2020,which included $11.2 million resulting from your July 10, 2020 reverse acquisitiontransaction with PCTI as disclosed on page 6 of Note 1. Please tell us how youdetermined that this wasn't a reverse acquisition of a public shell and a private operatingcompany. If you didn't consider the Company a shell company please describe the assetsand/or operations of the entity.Form 8-K/A filed September 25, 2020Item 9.01 - Financial Statements and Exhibits, page 0"
https://docoh.com/filing/1679817/0000000000-20-011995/OZSC-UPLOAD
https://docoh.com/filing/1679817/0001493152-20-023862/OZSC-CORRESP