SEC Comment Letter 0000000000-24-003997 to NANOPHASE TECHNOLOGIES Corp (NANX) (CIK 0000883107) (SLSN)
NANOPHASE TECHNOLOGIES Corp (NANX) (CIK 0000883107)
Date: April 12, 2024 · CIK: 0000883107 · Accession: 0000000000-24-003997
AI Filing Summary & Sentiment
File numbers found in text: 000-22333
Letter
United States securities and exchange commission logo April 12, 2024 Jess Jankowski President NANOPHASE TECHNOLOGIES Corp 1319 Marquette Drive Romeoville , Illinois 60446 Re:NANOPHASE TECHNOLOGIES Corp Form 10-K filed March 28, 2024 File No. 000-22333 Dear Jess Jankowski: We have reviewed your filing and have the following comments. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K filed March 28, 2024 Note 6, page F-14 1.We note that your incremental borrowing rate appears to approximate 9.5% (Note 3) whereas the discount rate you are using for leases is 7.1%. Please clarify for us how your accounting complies with the guidance in ASC 842-20-30-3. Provide the objective evidence you relied on in determining the 7.1% rate. We may have further comment. Note 15, page F-21 2.Please tell us how you intend to account for the $6 million Series X preferred stock transaction. It appears that since the majority stockholder may have effective control over the events triggering redemption, the analogous guidance in ASC480-10-S99.7 could be relevant. Your accounting analysis should also be provided in your March 31, 2024 Form 10-Q.
FirstName LastNameJess Jankowski Comapany NameNANOPHASE TECHNOLOGIES Corp April 12, 2024 Page 2 FirstName LastName Jess Jankowski NANOPHASE TECHNOLOGIES Corp April 12, 2024 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
April 12, 2024
Jess Jankowski
President
NANOPHASE TECHNOLOGIES Corp
1319 Marquette Drive
Romeoville , Illinois 60446
Re:NANOPHASE TECHNOLOGIES Corp
Form 10-K filed March 28, 2024
File No. 000-22333
Dear Jess Jankowski:
We have reviewed your filing and have the following comments. Please respond to this
letter within ten business days by providing the requested information or advise us as soon as
possible when you will respond. If you do not believe a comment applies to your facts and
circumstances, please tell us why in your response. After reviewing your response to this letter,
we may have additional comments.
Form 10-K filed March 28, 2024
Note 6, page F-14
1.We note that your incremental borrowing rate appears to approximate 9.5% (Note 3)
whereas the discount rate you are using for leases is 7.1%. Please clarify for us how your
accounting complies with the guidance in ASC 842-20-30-3. Provide the objective
evidence you relied on in determining the 7.1% rate. We may have further comment.
Note 15, page F-21
2.Please tell us how you intend to account for the $6 million Series X preferred stock
transaction. It appears that since the majority stockholder may have effective control over
the events triggering redemption, the analogous guidance in ASC480-10-S99.7 could be
relevant. Your accounting analysis should also be provided in your March 31, 2024 Form
10-Q.
FirstName LastNameJess Jankowski
Comapany NameNANOPHASE TECHNOLOGIES Corp
April 12, 2024 Page 2
FirstName LastName
Jess Jankowski
NANOPHASE TECHNOLOGIES Corp
April 12, 2024
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff. Please contact Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355
if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services