IPO - Blue Line Holdings, Inc.

Form Type: CORRESP

Filing Date: 2024-12-02

Corporate Action: Ipo

Type: New

Accession Number: 000149315224048281

Filing Summary: Blue Line Holdings, Inc. requests an acceleration of the effective date for its Registration Statement on Form S-1, seeking to make it effective by December 5, 2024, at 4:00 P.M. Eastern time. The Company acknowledges that the approval by the SEC does not exempt it from responsibility regarding the accuracy of the filing and does not serve as a defense in any potential enforcement action by the SEC or other parties regarding federal securities laws.

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Form Type: CORRESP

Filing Date: 2024-11-19

Corporate Action: Ipo

Type: Update

Accession Number: 000149315224046883

Filing Summary: Blue Line Holdings, Inc. has filed Amendment No. 2 to its Registration Statement on Form S-1 with the SEC in response to comments received from the staff. The document outlines revisions made to comply with various regulatory requirements, including changes to the wording and information on shareholders who purchased shares before the filing date. Specific revisions address comments about certain shareholders who could not have relied on the Registration Statement due to pre-existing relationships with the company. The filing also includes an interpretation regarding whether the offering should be classified as a secondary or an indirect primary offering, concluding that it is indeed a secondary offering. The selling shareholders have not engaged in any special selling methods, and none are acting as underwriters, backing the assertion of a true secondary offering under Rule 415. The company acknowledges the need for capital to implement its business plan, yet clarifies that proceeds from the selling shareholders will not benefit the company. This indicates a clear distinction from an indirect primary offering, reinforcing the nature of the registrations filed.

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