Golkor Inc (GKOR)

[Biochemist2002]

The reason the SEC mentioned that was because they were thinking it was an offering for participation in BVIG...which it was not. Essentially, they were saying, "Hey, we noticed the "distribution" on the website, we think it's actually an 'offering', so why didn't your filings indicate you did an offering."

That's why they questioned Ken about some "offering" they'd never heard of it before...As Ken eventually clarified, there was NO offer to begin with, just a distribution, therefore no reason for him to disclose an offering in previous filings. The problem was how the SEC was interpreting the "distribution." I had to see all the subsequent filings/letters they had to submit to tell the SEC that there was no "offering" before it made sense to me. The ONLY reason they mentioned in in Comment 1 on Oct 6th was because they thought the "distribution" was something else (an offering) that was not already reported to the SEC. But we didn't have to report it as an offering, because it was not. Does that make sense? It didn't make sense to me until I read all of the back and forth. As we see in the last communication, the SEC agreed that it was not an "offering" and let it go...

It was just an misunderstanding about the definition of the distribution.