United States securities and exchange commission logo
June 23, 2020
Jay Taragin
Chief Financial Officer
Annetta Acquisition Corp
640 Fifth Avenue, 12th Floor
New York, NY 10019
Re: Annetta Acquisition
Corp
Draft Registration
Statement on Form S-1
Submitted May 27,
2020
CIK 0001811210
Dear Mr. Taragin:
We have reviewed your
draft registration statement and have the following comment.
Please respond to this letter by providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. If you do not believe our comment applies to your facts and
circumstances or do not
believe an amendment is appropriate, please tell us why in your
response.
After reviewing the information you provide in response to this
comment and your
amended draft registration statement or filed registration statement, we
may have additional
comments.
Draft Registration Statement on Form S-1 submitted May 27, 2020
Summary, page 1
1. We note that the
Summary includes specific performance and valuation information for
Churchill Capital Corp.
For example, we note your discussion of CCC's total return and
1.5x multiple on
invested capital. Please remove from the Summary section this type
of performance and
valuation for companies other than the issuer. In addition, we note
that similar disclosure
appears in your Proposed Business section on page 77. If you
choose to retain this
performance information, please expand the disclosure to provide a
more balanced and
complete discussion of performance, including any material adverse
business developments.
Jay Taragin
FirstName LastNameJay Taragin
Annetta Acquisition Corp
Comapany NameAnnetta Acquisition Corp
June 23, 2020
Page 2
June 23, 2020 Page 2
FirstName LastName
You may contact Jeffrey Lewis at (202) 551-6216 or Shannon Menjivar at
(202) 551-
3856 if you have questions regarding comments on the financial statements and
related
matters. Please contact David Link at (202) 551-3356 or Erin E. Martin at (202)
551-3391 with
any other questions.
Sincerely,
Division of
Corporation Finance
Office of Real Estate
& Construction