SEC Comment Letter 0000000000-23-010291 to NOVAGANT CORP (NVGT) (CIK 0001089297)
NOVAGANT CORP (NVGT) (CIK 0001089297)
Date: Sept. 19, 2023 · CIK: 0001089297 · Accession: 0000000000-23-010291
AI Filing Summary & Sentiment
File numbers found in text: 000-26675
Letter
United States securities and exchange commission logo September 19, 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. 2 to Form 10-K for the Fiscal Year Ended March 31, 2023 File No. 000-26675 Dear WeiQun Chen: We have reviewed your September 13, 2023 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 17, 2023 letter. Amendment No. 2 to Form 10-K for the Fiscal Year Ended March 31, 2023 Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 42 1.We note your response to prior comment 2 and re-issue. 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 Communist Party. In this regard, we note that the "to our best knowledge" qualifier precedes the Item 9(C)(b)(5) disclosure. Please direct any questions to Jimmy McNamara at 202-551-7349 or Andrew Mew at 202-551-3377.
FirstName LastNameWeiQun Chen Comapany NameNovagant Corp September 19, 2023 Page 2 FirstName LastName WeiQun Chen Novagant Corp September 19, 2023 Page 2 Sincerely, Division of Corporation Finance Disclosure Review Program cc: Longling Guo
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United States securities and exchange commission logo
September 19, 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. 2 to Form 10-K for the Fiscal Year Ended March 31, 2023
File No. 000-26675
Dear WeiQun Chen:
We have reviewed your September 13, 2023 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment by providing the requested information or advise us as
soon as possible when you will respond. If you do not believe our comment applies to your facts
and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Unless we note otherwise, our references to prior comments are to comments in our August 17,
2023 letter.
Amendment No. 2 to Form 10-K for the Fiscal Year Ended March 31, 2023
Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 42
1.We note your response to prior comment 2 and re-issue. 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 Communist Party. In this regard, we
note that the "to our best knowledge" qualifier precedes the Item 9(C)(b)(5) disclosure.
Please direct any questions to Jimmy McNamara at 202-551-7349 or Andrew Mew at
202-551-3377.
FirstName LastNameWeiQun Chen
Comapany NameNovagant Corp
September 19, 2023 Page 2
FirstName LastName
WeiQun Chen
Novagant Corp
September 19, 2023
Page 2
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Longling Guo