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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

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Document Type
Confidence
SEC Posture
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Summary

Reasoning

File numbers found in text: 000-53957

Date
February 25, 2011
Author
A s s i s t a n t D i r e c t o r
Form
UPLOAD
Company
Golden Growers Cooperative (GGROU) (CIK 0001489874)

Letter

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

Show Raw Text
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