SEC Comment Letter for Golden Growers Cooperative (GGROU) (CIK 0001489874) (GGROU) — Feb 28, 2011
Golden Growers Cooperative (GGROU) (CIK 0001489874)
Date: Feb. 28, 2011 · CIK: 0001489874 · Accession: 0000000000-11-012488
AI Filing Summary & Sentiment
File numbers found in text: 000-53957
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February 25, 2011
Mark Dillon, Chief Executive Officer
Golden Growers Cooperative 112 Roberts Street North, Suite 111 Fargo, North Dakota 58102
Re: Golden Growers Cooperative
Form 10, Amendment 4 Filed December 20, 2010 File No. 000-53957
Dear Mr. Dillon:
We have reviewed your supplemental res ponse dated February 7, 2011 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.
If you do not believe our comments apply to your facts 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.
Financial Statements
Notes to Financial Statements
Restatement of Previously Issued Financial Statements, page F-7
1. We note you have restated your financial statements for th e fiscal year ended August
31, 2007, 2008 and 2009 and the four month period ended December 31, 2009.
Please file an Item 4.02 Form 8-K disclo sing such restatement or tell us why you
believe such filing is not required.
Mark Dillon, Chief Executive Officer
Golden Growers Cooperative February 25, 2011 Page 2
You may contact Jamie Kessel at (202) 551-3727 or Brian Bh andari at (202) 551-3390, if
you have questions regarding the financial statements and relate d matters. Please contact Susann
Reilly at (202) 551-3236 or David Link at (202) 551-3356 with other questions.
Sincerely, /s/ David Link for John Reynolds
A s s i s t a n t D i r e c t o r
Office of Beverages, Apparel and Health Care Services