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SEC Comment Letter for Enlightify Inc. (ENFY) (CIK 0000857949) (ENFY) — Jul 18, 2012

Enlightify Inc. (ENFY) (CIK 0000857949)
Date: July 18, 2012 · CIK: 0000857949 · Accession: 0000000000-12-037631

Financial Reporting Regulatory Compliance Risk Disclosure

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Reasoning

Referenced dates: July 11, 2012

Date
June 30, 2011
Author
/s/ David R. Humphrey
Form
UPLOAD
Company
Enlightify Inc. (ENFY) (CIK 0000857949)

Letter

July 18 , 2012 China Green Agriculture, Inc. Mr. Ken Ren Chief Financial Officer 3 rd Floor, Borough A, Block A, No. 181 South Taibai Road, Xi’an, Shaanxi Province People’s Republic of China 710065

Re: China Green Agriculture, Inc. Form 10-K for the Fiscal Year E nded June 30, 2011 Filed September 12, 2011 File No. 001 -34260

Dear Mr. Ren :

We have reviewed your response dated July 11, 2012 and have the following comments. In some of our comm ents, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. 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 respons e.

After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.

Form 10 -K for the Fiscal Year Ended June 30, 2011

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations

Results of Operations

Discussion of Segment Profitability Measures, page 53

1. Refer to your response to our prior comment 5. In your Form 10 -K for the fiscal year ended June 30, 2012, please expand your comparative discussion of operations to include all of the disclosures with respect to Jintai that have been provided to the staff on pages 3 and 4 of your letter dated July 11, 2012. Please note, for future filings, that the disclosure requirements of Item 303 (a) (3) (i) and (ii ) of Regulation S -K require the description of significant economic changes and known trends, events or uncertainties that may reasonably be expected to have a

Ken Ren China Green Agriculture, Inc. July 18 , 2012 Page 2

material impact upon revenues or income from continuing operations. This would include a comple te and timely discussion of segment information where it is appropriate to an understanding of the business.

Note 7 – Land Use Right, page F -14

2. Refer to our previous comments 10 and 11. Please revise your disclosure in future filings to include a narrat ive similar to that included in your response to these comments. Specifically, you should discuss the progress of receiving the land use right, the probability you might not receive it, the reasons why it may not be granted, and the financial exposure in RMB and USD as included comment 11.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchang e Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

In responding to our comments, please provide a written statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the disclosure in the filing;

staff comments or changes to disclosure in response to staff comments do not foreclose the Commissi on from taking any action with respect to the filing; and

the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

You may contact Amy Gedde s at 202 -551-3304 or Margery Reich at 202 -551-3347 if you have questions regarding comments on the financial statements and related matters. Please contact me at 202-551-3211 with any other questions.

Sincerely,
/s/ David R. Humphrey

Show Raw Text
July 18 , 2012

China Green Agriculture, Inc.
Mr. Ken Ren
Chief Financial Officer
3 rd Floor, Borough A, Block A, No. 181
South Taibai Road, Xi’an, Shaanxi Province
People’s Republic of China 710065

Re: China Green Agriculture, Inc.
 Form 10-K for the Fiscal Year E nded June 30, 2011
Filed September 12, 2011
File No. 001 -34260

Dear Mr. Ren :

We have reviewed your response dated July 11, 2012  and have the following comments.
In some of our comm ents, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   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 respons e.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 10 -K for the Fiscal Year Ended June 30, 2011

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Results of Operations

Discussion of Segment Profitability Measures, page 53

1. Refer to your response to our prior comment 5.  In your Form 10 -K for the fiscal year ended
June 30, 2012, please expand your comparative discussion of operations to include all of the
disclosures with respect to Jintai that have been provided to the staff on pages 3 and 4 of your
letter dated July 11, 2012.  Please note, for future filings, that the disclosure requirements of
Item 303 (a) (3) (i) and (ii ) of Regulation S -K require the description of significant economic
changes and known trends, events or uncertainties that may reasonably be expected to have a

Ken Ren
China Green Agriculture, Inc.
July 18 , 2012
Page 2

 material impact upon revenues or income from continuing operations.  This would include a
comple te and timely discussion of segment information where it is appropriate to an
understanding of the business.

Note 7 – Land Use Right, page F -14

2. Refer to our previous comments 10 and 11.  Please revise your disclosure in future filings to
include a narrat ive similar to that included in your response to these comments.  Specifically,
you should discuss the progress of receiving the land use right, the probability you might not
receive it, the reasons why it may not be granted, and the financial exposure in RMB and
USD as included comment 11.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchang e Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commissi on from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Amy Gedde s at 202 -551-3304 or Margery Reich at 202 -551-3347  if
you have questions regarding comments on the financial statements and related matters.  Please
contact me at 202-551-3211  with any other questions.

Sincerely,

 /s/ David R. Humphrey

David R. Humphrey
Accounting Branch Chief