Rivulet Entertainment, Inc. responded to SEC staff comments on business combinations
Letter dated
2025-02-26; published on EDGAR 2026-02-11 — the
SEC releases comment letters only after the review closes.
We note that you have inconsistent disclosures about your recent issuance of 90,784,800 shares and payment of $10,069,000, indicating you arranged to acquire "the assets of" Rivulet Media, Inc. (the Seller identified in the agreement attached to the Form 8-K that you filed on March 7, 2024), while also indicating you intend to account for the transaction as a reverse merger, as if you acquired the Seller instead.…
Evidence
Cited sections
Note 7 - Asset Purchase Agreement, page 19
Direction
company to staff
Letter dated
2025-02-26
Published on edgar
2026-02-11
Reviewing
Rivulet Entertainment, Inc. Form 10-KT for the Transition Period ended June 30, 2024 Filed November 12, 2024 File No. 000-52390 Dear Mr. Cannarella and Mr. Hill
Source
Company response to SEC staff (CORRESP)
Topics
Business combinations
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.
Rivulet Entertainment, Inc. responded to SEC staff comments on business combinations
Letter dated
2025-03-26; published on EDGAR 2026-02-11 — the
SEC releases comment letters only after the review closes.
We note your response to prior comment one explaining that shares transferred to Rivulet Media, Inc. were recognized as a prepayment for the pending transaction, although without addressing the inconsistency between the $29,894,641 value ascribed to the prepayment shares and the value that would reflect the combined equity or deficit of the entities acquired, as would result in accounting for a reverse…
Evidence
Cited sections
Note 7 - Asset Purchase Agreement, page 19
Direction
company to staff
Letter dated
2025-03-26
Published on edgar
2026-02-11
Reviewing
Rivulet Entertainment, Inc. Form 10-KT for the Transition Period ended June 30, 2024 Filed November 12, 2024 File No. 000-52390 Dear Mr. Cannarella and Mr. Hill
Source
Company response to SEC staff (CORRESP)
Topics
Business combinations, Fair value, MD&A
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.
Rivulet Entertainment, Inc. responded to SEC staff comments on business combinations
Letter dated
2025-05-12; published on EDGAR 2026-02-11 — the
SEC releases comment letters only after the review closes.
We note that you included language from our first comment of our February 19, 2025 letter along with your more recent response to comment one. Such language had referenced conflicting disclosures in your filing as to whether you would merge with a business or engage in an asset acquisition, and we asked that you explain to us how you evaluated the transaction relative to the guidance in FASB ASC 805-10-55-3A through…
Evidence
Cited sections
Note 7 - Asset Purchase Agreement, page 19
Direction
company to staff
Letter dated
2025-05-12
Published on edgar
2026-02-11
Reviewing
Rivulet Entertainment, Inc. Form 10-KT for the Transition Period ended June 30, 2024 Filed November 12, 2024 File No. 000-52390 Dear Mr. Cannarella and Mr. Hill
Source
Company response to SEC staff (CORRESP)
Topics
Business combinations, Fair value, Goodwill and impairment
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.
Rivulet Entertainment, Inc. responded to SEC staff comments on business combinations
Letter dated
2025-08-26; published on EDGAR 2026-02-11 — the
SEC releases comment letters only after the review closes.
We note that your interim reports for the quarters ended September 30, 2024 and December 31, 2024 reflect the acquisition from the standpoint of the accounting acquirer in your July 7, 2024 reverse merger, although as discussed with your representative during a telephone conference on August 20, 2025, an inconsistent approach was taken in presenting share activity within the equity statements of these two reports.…
Evidence
Direction
company to staff
Letter dated
2025-08-26
Published on edgar
2026-02-11
Reviewing
Rivulet Entertainment, Inc. Form 10-KT for the Transition Period ended June 30, 2024 Filed November 12, 2024 File No. 000-52390 Dear Mr. Cannarella and Mr. Hill
Source
Company response to SEC staff (CORRESP)
Topics
Business combinations
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.
SEC staff questioned Rivulet Entertainment, Inc.'s accounting for business combinations
Letter dated
2025-02-19; published on EDGAR 2026-02-11 — the
SEC releases comment letters only after the review closes.
We note that you have inconsistent disclosures about your recent issuance of 90,784,800 shares and payment of $10,069,000, indicating you arranged to acquire "the assets of" Rivulet Media, Inc. (the Seller identified in the agreement attached to the Form 8-K that you filed on March 7, 2024), while also indicating you intend to account for the transaction as a reverse merger, as if you acquired the Seller instead.…
Evidence
Cited sections
Note 7 - Asset Purchase Agreement, page 19
Direction
staff to company
Letter dated
2025-02-19
Published on edgar
2026-02-11
Reviewing
Rivulet Entertainment, Inc. Form 10-KT for the Transition Period ended June 30, 2024 Filed November 12, 2024 File No. 000-52390 Dear Walter Geldenhuys: We have
Source
SEC staff comment letter (UPLOAD)
Topics
Business combinations
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.
SEC staff questioned Rivulet Entertainment, Inc.'s accounting for business combinations
Letter dated
2025-03-05; published on EDGAR 2026-02-11 — the
SEC releases comment letters only after the review closes.
We note your response to prior comment one explaining that shares transferred to Rivulet Media, Inc. were recognized as a prepayment for the pending transaction, although without addressing the inconsistency between the $29,894,641 value ascribed to the prepayment shares and the value that would reflect the combined equity or deficit of the entities acquired, as would result in accounting for a reverse…
Evidence
Cited sections
Note 7 - Asset Purchase Agreement, page 19
Direction
staff to company
Letter dated
2025-03-05
Published on edgar
2026-02-11
Reviewing
Rivulet Entertainment, Inc. Form 10-KT for the Transition Period ended June 30, 2024 Filed November 12, 2024 File No. 000-52390 Dear Walter Geldenhuys: We have
Source
SEC staff comment letter (UPLOAD)
Topics
Business combinations
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.
SEC staff questioned Rivulet Entertainment, Inc.'s accounting for business combinations
Letter dated
2025-04-07; published on EDGAR 2026-02-11 — the
SEC releases comment letters only after the review closes.
We note that you included language from our first comment of our February 19, 2025 letter along with your more recent response to comment one. Such language had referenced conflicting disclosures in your filing as to whether you would merge with a business or engage in an asset acquisition, and we asked that you explain to us how you evaluated the transaction relative to the guidance in FASB ASC 805-10-55-3A through…
Evidence
Cited sections
Note 7 - Asset Purchase Agreement, page 19
Direction
staff to company
Letter dated
2025-04-07
Published on edgar
2026-02-11
Reviewing
Rivulet Entertainment, Inc. Form 10-KT for the Transition Period ended June 30, 2024 Filed November 12, 2024 File No. 000-52390 Dear Walter Geldenhuys: We have
Source
SEC staff comment letter (UPLOAD)
Topics
Business combinations, Fair value, Goodwill and impairment
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.
SEC staff questioned Rivulet Entertainment, Inc.'s accounting for business combinations
Letter dated
2025-08-22; published on EDGAR 2026-02-11 — the
SEC releases comment letters only after the review closes.
We note that your interim reports for the quarters ended September 30, 2024 and December 31, 2024 reflect the acquisition from the standpoint of the accounting acquirer in your July 7, 2024 reverse merger, although as discussed with your representative during a telephone conference on August 20, 2025, an inconsistent approach was taken in presenting share activity within the equity statements of these two reports.…
Evidence
Direction
staff to company
Letter dated
2025-08-22
Published on edgar
2026-02-11
Reviewing
Rivulet Entertainment, Inc. Form 10-KT for the Transition Period ended June 30, 2024 Filed November 12, 2024 File No. 000-52390 Dear Walter Geldenhuys: We have
Source
SEC staff comment letter (UPLOAD)
Topics
Business combinations
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.