SEC Comment Letter 0000000000-24-011200 to RANGE IMPACT, INC. (RNGE) (CIK 0001438943) (RNGE)
RANGE IMPACT, INC. (RNGE) (CIK 0001438943)
Date: Oct. 3, 2024 · CIK: 0001438943 · Accession: 0000000000-24-011200
AI Filing Summary & Sentiment
File numbers found in text: 000-53832
Letter
October 3, 2024 Michael Cavanaugh Chief Executive Officer RANGE IMPACT, INC. 200 Park Avenue, Suite 400 Cleveland, Ohio 44122 Re:RANGE IMPACT, INC. Amendment No. 1 to Annual Report on Form 10-K Amendment No. 1 to Quarterly Report on Form 10-Q Filed August 8, 2024 File No. 000-53832 Dear Michael Cavanaugh: We have reviewed your filings 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. Amendment No.1 to Form 10-K filed August 8, 2024 Mine Safety Disclosures , page 36 1.We note your response to prior comment 1 that you ceased being the operator of a coal or other mine effective December 29, 2023, and therefore, no disclosures under Item 104 of Regulation S-K were required in filings for periods after such date. Please reconcile this response with your disclosure in your Form 10-Q, filed August 14, 2024, regarding your statement that Range Minerals subcontracted mining activities and that on May 1, 2024, Range Minerals contracted with a mining contractor at the Fola mining site in West Virginia. It appears, based on these disclosures that you continue to conduct mining activities. Please provide the Mine Safety Disclosure required by Item 4 in Part II of Form 10-Q or explain how you concluded such disclosure is not required. Form 10-Q/A filed August 8, 2024 2. Restatement of Previously Reported Financial Statements, page 13 We note that you reported a significant restatement to your reported Cost of Services as of 2.
October 3, 2024 Page 2 March 31, 2024. Please clarify to us how you evaluated the current report requirements under Item 4.02 of Form 8-K or file any required current reports as needed. 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 Babette Cooper at 202-551-3396 or Wilson Lee at 202-551-3468 if you have questions regarding comments on the financial statements and related matters. Please contact Ruairi Regan at 202-551-3269 or David Link at 202-551-3356 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc:Howard M. Groedel, Esq.
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October 3, 2024
Michael Cavanaugh
Chief Executive Officer
RANGE IMPACT, INC.
200 Park Avenue, Suite 400
Cleveland, Ohio 44122
Re:RANGE IMPACT, INC.
Amendment No. 1 to Annual Report on Form 10-K
Amendment No. 1 to Quarterly Report on Form 10-Q
Filed August 8, 2024
File No. 000-53832
Dear Michael Cavanaugh:
We have reviewed your filings 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.
Amendment No.1 to Form 10-K filed August 8, 2024
Mine Safety Disclosures , page 36
1.We note your response to prior comment 1 that you ceased being the operator of a coal or
other mine effective December 29, 2023, and therefore, no disclosures under Item 104 of
Regulation S-K were required in filings for periods after such date. Please reconcile this
response with your disclosure in your Form 10-Q, filed August 14, 2024, regarding your
statement that Range Minerals subcontracted mining activities and that on May 1, 2024,
Range Minerals contracted with a mining contractor at the Fola mining site in West
Virginia. It appears, based on these disclosures that you continue to conduct mining
activities. Please provide the Mine Safety Disclosure required by Item 4 in Part II of Form
10-Q or explain how you concluded such disclosure is not required.
Form 10-Q/A filed August 8, 2024
2. Restatement of Previously Reported Financial Statements, page 13
We note that you reported a significant restatement to your reported Cost of Services as of 2.
October 3, 2024
Page 2
March 31, 2024. Please clarify to us how you evaluated the current report requirements
under Item 4.02 of Form 8-K or file any required current reports as needed.
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 Babette Cooper at 202-551-3396 or Wilson Lee at 202-551-3468 if you
have questions regarding comments on the financial statements and related matters. Please
contact Ruairi Regan at 202-551-3269 or David Link at 202-551-3356 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Howard M. Groedel, Esq.