SEC Comment Letter 0000000000-24-003079 to Green Giant Inc. (CIK 0001158420)
Green Giant Inc. (CIK 0001158420)
Date: March 21, 2024 · CIK: 0001158420 · Accession: 0000000000-24-003079
AI Filing Summary & Sentiment
File numbers found in text: 001-34864
Letter
United States securities and exchange commission logo March 20, 2024 Rongrong Dai Chief Financial Officer Green Giant Inc. 6 Xinghan Road, 19th Floor Hanzhong City Shaanxi Province, PRC 723000 Re:Green Giant Inc. Form 10-K for Fiscal Year Ended September 30, 2023 Filed December 28, 2023 File No. 001-34864 Dear Rongrong Dai: 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 for Fiscal Year Ended September 30, 2023 Consolidated Statements of Operations and Comprehensive Loss, page F-5 1.We note that for the year ended September 30, 2023, 51.1% of your revenues came from battery recycling. However, no such revenues were earned for the period ended December 31, 2023 and disclosure in your 10-Q indicates that you are still searching for a warehouse for your battery recycling production. On page 2 of the 10-K you disclose that in April 2023, you started the trading of metals to leverage the fluctuation in their prices. Please clarify whether you have begun recycling from batteries or if revenues recognized during the year ended September 30, 2023 are gains from trading in metals. 2.We note your impairment of real estate property under development of $ 72.3 million and $ 73.6 million for the years ended September 30, 2023 and 2022, respectively. Please explain to us in detail your basis for including this impairment line as an operating expense for each of the years rather than as a component of cost of real estate sales to arrive at gross profit (loss). In your response please clarify which real estate projects were
FirstName LastNameRongrong Dai Comapany NameGreen Giant Inc. March 20, 2024 Page 2 FirstName LastName Rongrong Dai Green Giant Inc. March 20, 2024 Page 2 impaired, the reason for impairment and cite the applicable accounting guidance used in making your determination. General 3.We issued comment letters on October 25, 2023 and on February 21, 2024 on the Form F- 4 initially filed by Green Giant Enterprise Inc. on October 3, 2023 and the preliminary proxy statements filed by Green Giant Inc. Please make the appropriate corresponding changes in your future periodic reports for the comments issued on the Form F-4, as applicable. 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 William Demarest at 202-551-3432 or Isaac Esquivel at 202-551-3395 if you have questions regarding comments on the financial statements and related matters. Please contact Ronald (Ron) E. Alper at 202-551-3329 or David Link at 202-551-3356 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Joan Wu
Show Raw Text
United States securities and exchange commission logo
March 20, 2024
Rongrong Dai
Chief Financial Officer
Green Giant Inc.
6 Xinghan Road, 19th Floor
Hanzhong City
Shaanxi Province, PRC 723000
Re:Green Giant Inc.
Form 10-K for Fiscal Year Ended September 30, 2023
Filed December 28, 2023
File No. 001-34864
Dear Rongrong Dai:
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 for Fiscal Year Ended September 30, 2023
Consolidated Statements of Operations and Comprehensive Loss, page F-5
1.We note that for the year ended September 30, 2023, 51.1% of your revenues came from
battery recycling. However, no such revenues were earned for the period ended
December 31, 2023 and disclosure in your 10-Q indicates that you are still searching for a
warehouse for your battery recycling production. On page 2 of the 10-K you disclose that
in April 2023, you started the trading of metals to leverage the fluctuation in their prices.
Please clarify whether you have begun recycling from batteries or if revenues recognized
during the year ended September 30, 2023 are gains from trading in metals.
2.We note your impairment of real estate property under development of $ 72.3 million and
$ 73.6 million for the years ended September 30, 2023 and 2022, respectively.
Please explain to us in detail your basis for including this impairment line as an operating
expense for each of the years rather than as a component of cost of real estate sales to
arrive at gross profit (loss). In your response please clarify which real estate projects were
FirstName LastNameRongrong Dai
Comapany NameGreen Giant Inc.
March 20, 2024 Page 2
FirstName LastName
Rongrong Dai
Green Giant Inc.
March 20, 2024
Page 2
impaired, the reason for impairment and cite the applicable accounting guidance used in
making your determination.
General
3.We issued comment letters on October 25, 2023 and on February 21, 2024 on the Form F-
4 initially filed by Green Giant Enterprise Inc. on October 3, 2023 and the preliminary
proxy statements filed by Green Giant Inc. Please make the appropriate corresponding
changes in your future periodic reports for the comments issued on the Form F-4, as
applicable.
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 William Demarest at 202-551-3432 or Isaac Esquivel at 202-551-3395 if
you have questions regarding comments on the financial statements and related matters. Please
contact Ronald (Ron) E. Alper at 202-551-3329 or David Link at 202-551-3356 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Joan Wu