SEC Comment Letter for Alto Ingredients, Inc. (ALTO) (CIK 0000778164) (ALTO) — May 4, 2015
Alto Ingredients, Inc. (ALTO) (CIK 0000778164)
Date: May 4, 2015 · CIK: 0000778164 · Accession: 0000000000-15-024372
AI Filing Summary & Sentiment
Reasoning
Letter
May 1 , 2015 Via E -Mail Christopher Wright , Esq. Vice President and General Counsel Pacific Ethanol, Inc. 400 Capitol Mall, Suite 2060 Sacramento, CA 95814
Re: Pacific Ethanol, Inc. Amendment No. 2 to Registration Statement on Form S -4 Filed April 2 1, 2015 File No. 333 -201879
Dear Mr. Wright :
We have reviewed your amended registration statement and have the following comment .
Please respond to this letter by amending your registration statement and providing the requested information . 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 reviewi ng any amendment to your registration statement and the information you provide in response to this comment , we may have additional comments.
Aventine Forward -Looking Financial Information, page 26
1. We note your response to comment 3 of our letter dated April 16 , 2015 and we re -issue our comment. Please disclose why Aventine did not provide projections for the combined company and how, if at all, the lack of such combined projections influenced its conclusions .
You may contact Ameen Hamady (Staff Accou ntant) at 202-551-3891 or Terence O’Brien (Accounting Branch Chief) at 202-551-3355 if you have questions regarding comments on the financial statements and related matters. Please contact Frank Pigott (Staff Attorney) at 202-551-3570 or Craig Slivka (Spe cial Counsel) at 202-551-3729 with any other questions.
Christopher Wright Pacific Ethanol, Inc. May 1 , 2015 Page 2
Sincerely,
/s/ Craig Slivka, for
Show Raw Text
May 1 , 2015 Via E -Mail Christopher Wright , Esq. Vice President and General Counsel Pacific Ethanol, Inc. 400 Capitol Mall, Suite 2060 Sacramento, CA 95814 Re: Pacific Ethanol, Inc. Amendment No. 2 to Registration Statement on Form S -4 Filed April 2 1, 2015 File No. 333 -201879 Dear Mr. Wright : We have reviewed your amended registration statement and have the following comment . Please respond to this letter by amending your registration statement and providing the requested information . 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 reviewi ng any amendment to your registration statement and the information you provide in response to this comment , we may have additional comments. Aventine Forward -Looking Financial Information, page 26 1. We note your response to comment 3 of our letter dated April 16 , 2015 and we re -issue our comment. Please disclose why Aventine did not provide projections for the combined company and how, if at all, the lack of such combined projections influenced its conclusions . You may contact Ameen Hamady (Staff Accou ntant) at 202-551-3891 or Terence O’Brien (Accounting Branch Chief) at 202-551-3355 if you have questions regarding comments on the financial statements and related matters. Please contact Frank Pigott (Staff Attorney) at 202-551-3570 or Craig Slivka (Spe cial Counsel) at 202-551-3729 with any other questions. Christopher Wright Pacific Ethanol, Inc. May 1 , 2015 Page 2 Sincerely, /s/ Craig Slivka, for Pamela Long Assistant Director Cc: Via E -Mail Larry A. Cerutti , Esq. Troutman Sanders LLP 5 Park Plaza, Suite 1400 Irvine, CA 92614 -2545