SEC Comment Letter 0000000000-23-009026 to NOVAGANT CORP (NVGT) (CIK 0001089297)
NOVAGANT CORP (NVGT) (CIK 0001089297)
Date: Aug. 17, 2023 · CIK: 0001089297 · Accession: 0000000000-23-009026
AI Filing Summary & Sentiment
File numbers found in text: 000-26675
Letter
United States securities and exchange commission logo August 17, 2023 WeiQun Chen Chief Financial Officer Novagant Corp Suite 2006, AIA Kowloon Tower, Landmark East 100 How Ming Street KT, Hong Kong 999077 Re:Novagant Corp Amendment No. 1 to Form 10-K for the Fiscal Year Ended March 31, 2023 File No. 000-26675 Dear WeiQun Chen: We have reviewed your August 14, 2023 response to our comment letter 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 these comments 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 our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 26, 2023 letter. Amendment No. 1 to Form 10-K for the Fiscal Year Ended March 31, 2023 General 1.We note your response to comment 3 and re-issue in part. We note in your supplemental submission that “as of the date hereof, the directors, officers and senior management of the Company consist of: WeiQun Chen, HongZhen Xu and HaiYan Zeng, and none of such persons are a representative of a government entity in the People’s Republic of China.” Please confirm, if true, that your reference to “representative” includes officials of the Chinese Community Party. 2.With respect to your disclosure pursuant to Item 9C(b)(5), we note that you have included language that such disclosure is “to our best knowledge.” Please supplementally confirm without qualification, if true, that your articles and the articles of your consolidated foreign operating entities do not contain wording from any charter of the Chinese
FirstName LastNameWeiQun Chen Comapany NameNovagant Corp August 17, 2023 Page 2 FirstName LastName WeiQun Chen Novagant Corp August 17, 2023 Page 2 Communist Party. 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 Jimmy McNamara at 202-551-7349 or Andrew Mew at 202-551-3377 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program
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United States securities and exchange commission logo
August 17, 2023
WeiQun Chen
Chief Financial Officer
Novagant Corp
Suite 2006, AIA Kowloon Tower, Landmark East
100 How Ming Street
KT, Hong Kong 999077
Re:Novagant Corp
Amendment No. 1 to Form 10-K for the Fiscal Year Ended March 31, 2023
File No. 000-26675
Dear WeiQun Chen:
We have reviewed your August 14, 2023 response to our comment letter 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
July 26, 2023 letter.
Amendment No. 1 to Form 10-K for the Fiscal Year Ended March 31, 2023
General
1.We note your response to comment 3 and re-issue in part. We note in your supplemental
submission that “as of the date hereof, the directors, officers and senior management of
the Company consist of: WeiQun Chen, HongZhen Xu and HaiYan Zeng, and none of
such persons are a representative of a government entity in the People’s Republic of
China.” Please confirm, if true, that your reference to “representative” includes officials
of the Chinese Community Party.
2.With respect to your disclosure pursuant to Item 9C(b)(5), we note that you have included
language that such disclosure is “to our best knowledge.” Please supplementally confirm
without qualification, if true, that your articles and the articles of your consolidated
foreign operating entities do not contain wording from any charter of the Chinese
FirstName LastNameWeiQun Chen
Comapany NameNovagant Corp
August 17, 2023 Page 2
FirstName LastName
WeiQun Chen
Novagant Corp
August 17, 2023
Page 2
Communist Party.
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 Jimmy McNamara at 202-551-7349 or Andrew Mew at 202-551-3377
with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program