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Rahkus

08/02/25 6:40 PM

#20830 RE: Ribo #20829


If Amendment No. 3 has not been filed yet, then the SEC review is still active, and the Form 10 is still in draft status not effective under Section 12(g).

Respectfully, I believe you’re misapplying SEC 116.06.

That rule only applies after the Form 10 has been filed and 60 calendar days have passed without further amendments.  If RITE is still submitting responses to SEC comments (an upcoming third amendment), then the effective date hasn’t arrived.


RITE hasn’t filed the third amendment yet, so the 60-day countdown hasn’t even started. Every time they update the Form 10 (to fix things the SEC asked about), the clock resets.

So until they file the final version and leave it untouched for 60 days, the Form 10 doesn’t go effective. That means RITE is not yet officially a fully-reporting company under SEC rules.

Your statement only applies AFTER that 60-day period ends WITHOUT new changes.

Respectfully, Form 10 isn’t effective yet if the third amendment hasn’t been filed.
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MegaMagician86

08/03/25 5:38 PM

#20842 RE: Ribo #20829

Rashkus --- you are right on so many things, but you are wrong on your statement that the Form 10 is not effective.

It is effective.

It went effective months ago. A Form 10 can be effective while the Company and SEC continue to discuss matters contained within the document. The Company is subject to reporting requirements already -- even though the Company has not reached the "no comment" stage.

Having said that, you have been spot on with most of your comments -- it is obvious you have done your research well.