SEC Comment Letter for Future FinTech Group Inc. (FTFT) (CIK 0001066923) (FTFT) — Mar 15, 2011
Future FinTech Group Inc. (FTFT) (CIK 0001066923)
Date: March 15, 2011 · CIK: 0001066923 · Accession: 0000000000-11-015962
AI Filing Summary & Sentiment
Reasoning
Referenced dates: January 18, 2011
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE March 15, 2011 Via U.S. Mail and Facsimile 86-29-88377295 Ms. Spring Liu Chief Financial Officer Skypeople Fruit Juice, Inc. 16F, National Development Bank Tower No.2, Gaoxin 1 st Road Xi’an, People’s Republic of China Re: Skypeople Fruit Juice, Inc. Form 10-K for the Fiscal Year Ended December 31, 2009 Filed March 31, 2010 File No. 1-14523
Dear Ms. Liu: We have reviewed your response filed on February 7, 2011 and have the following comment. 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 within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response.
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 December 31, 2009
Notes to Consolidated Financial Statements, page 81
General
1. Your response to prior comment numbe r 1 from our letter dated January 18, 2011 indicates that, while segment reporting coul d be based on product information, you do not believe that the second and third criteria under ASC paragraph 280-10-50-1 are met.
Ms. Spring Liu Skypeople Fruit Juice, Inc. March 15, 2011 Page 2 With respect to the second criteria, you indicate that you do no t allocate operating expenses and other expenses based on produc ts. Based on this, you have concluded that you do not have discrete financial informa tion based on products. ASC paragraph 280- 10-50-1 does not specify the nature or format of discrete financial information, and does not indicate a particular perfor mance measure that must be disclosed. The disclosure you have provided in your MD&A and various earn ings and investor pr esentations regarding sales, cost of sales and gross margins for va rious products indicates that, for purposes of segment reporting, you do have discrete financial information.
With respect to the third criteria, you indica te that your CODM a llocates resources and reviews the overall performance of the comp any as a whole. However, disclosure provided in your MD&A and vari ous earnings and investor pr esentations indicates that performance is evaluated, and expansion and other resource allocation decisions are made, based on product information.
In view of these factors, it is not clear to us why you belie ve that segment reporting on the basis of products is not required. Accord ingly, revise your pres entation to include disaggregated segment information, or provide additional information or analysis that supports your current presentation. You may contact Bob Carroll at (202) 551-3362, or me at (202) 551-3489 if you have questions regarding comments on the financial stat ements and related matters. S i n c e r e l y , / s / B r a d S k i n n e r B r a d S k i n n e r Senior Assistant Chief Accountant
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
March 15, 2011
Via U.S. Mail and Facsimile 86-29-88377295
Ms. Spring Liu
Chief Financial Officer Skypeople Fruit Juice, Inc. 16F, National Development Bank Tower No.2, Gaoxin 1
st Road
Xi’an, People’s Republic of China
Re: Skypeople Fruit Juice, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2009
Filed March 31, 2010
File No. 1-14523
Dear Ms. Liu:
We have reviewed your response filed on February 7, 2011 and have the following
comment. 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 within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response. If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
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 December 31, 2009
Notes to Consolidated Financial Statements, page 81
General
1. Your response to prior comment numbe r 1 from our letter dated January 18, 2011
indicates that, while segment reporting coul d be based on product information, you do
not believe that the second and third criteria under ASC paragraph 280-10-50-1 are met.
Ms. Spring Liu
Skypeople Fruit Juice, Inc. March 15, 2011 Page 2
With respect to the second criteria, you indicate that you do no t allocate operating
expenses and other expenses based on produc ts. Based on this, you have concluded that
you do not have discrete financial informa tion based on products. ASC paragraph 280-
10-50-1 does not specify the nature or format of discrete financial information, and does
not indicate a particular perfor mance measure that must be disclosed. The disclosure you
have provided in your MD&A and various earn ings and investor pr esentations regarding
sales, cost of sales and gross margins for va rious products indicates that, for purposes of
segment reporting, you do have discrete financial information.
With respect to the third criteria, you indica te that your CODM a llocates resources and
reviews the overall performance of the comp any as a whole. However, disclosure
provided in your MD&A and vari ous earnings and investor pr esentations indicates that
performance is evaluated, and expansion and other resource allocation decisions are
made, based on product information.
In view of these factors, it is not clear to us why you belie ve that segment reporting on
the basis of products is not required. Accord ingly, revise your pres entation to include
disaggregated segment information, or provide additional information or analysis that
supports your current presentation.
You may contact Bob Carroll at (202) 551-3362, or me at (202) 551-3489 if you have questions
regarding comments on the financial stat ements and related matters.
S i n c e r e l y , / s / B r a d S k i n n e r B r a d S k i n n e r Senior Assistant Chief Accountant