United States securities and exchange commission logo
September 10, 2020
Khurram P. Sheikh
Chief Executive Officer
KINS Technology Group Inc.
Four Palo Alto Square, Suite 200
3000 El Camino Real
Palo Alto, CA 94306
Re: KINS Technology
Group Inc.
Draft Registration
Statement on Form S-1
Submitted August
14, 2020
CIK No. 0001820875
Dear Mr. Sheikh:
We have reviewed your draft registration statement and have the
following comments. In
some of our comments, we may ask you to provide us with information so
we may better
understand your disclosure.
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 comments apply 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 these
comments and your
amended draft registration statement or filed registration statement, we
may have additional
comments.
Draft Registration Statement on Form S-1 submitted August 14, 2020
Our certificate of incorporation will require . . ., page 73
1. We note your disclosure
that the exclusive forum provision in your certificate of
incorporation will not
apply to suits brought to enforce a duty or liability created by the
Securities Act, the
Exchange Act or any other claim for which federal courts have
exclusive jurisdiction.
Please revise your disclosure to state that investors will not be
deemed to have waived
the company s compliance with the federal securities laws and the
rules and regulations
thereunder. Your certificate of incorporation, filed as Exhibit 3.1,
does not reference
either Act. If the exclusive forum provision does not apply to actions
arising under the
Securities Act or Exchange Act, please ensure that the exclusive forum
Khurram P. Sheikh
KINS Technology Group Inc.
September 10, 2020
Page 2
provision in the governing documents states this clearly, or tell us how
you will inform
investors in future filings that the provision does not apply to any
actions arising under the
Securities Act or Exchange Act.
You may contact Heather Clark, Staff Accountant, at 202-551-3624 or Jean
Yu, Assistant
Chief Accountant, at 202-551-3305 if you have questions regarding comments on
the financial
statements and related matters. Please contact Thomas Jones, Staff Attorney, at
202-551-3602 or
Sherry Haywood, Staff Attorney, at 202-551-3345 with any other questions.
Sincerely,
FirstName LastNameKhurram P. Sheikh
Division of
Corporation Finance
Comapany NameKINS Technology Group Inc.
Office of
Manufacturing
September 10, 2020 Page 2
cc: Gregg A.Noel, Esq.
FirstName LastName