SEC Company Response from Golden Growers Cooperative (GGROU) (CIK 0001489874) (GGROU) — Mar 1, 2011
Golden Growers Cooperative (GGROU) (CIK 0001489874)
Date: March 1, 2011 · CIK: 0001489874 · Accession: 0001104659-11-011442
AI Filing Summary & Sentiment
Reasoning
Referenced dates: February 25, 2011
Letter
VIA EDGAR CORRESPONDENCE AND FACSIMILE Securities and Exchange Commission Golden Growers Cooperative Form 10, Amendment 4 Filed December 20, 2010 File No. 0-53957
Re:
Dear Mr. Reynolds:
We are writing in response to your letter dated February 25, 2011, regarding the Registration Statement as amended on Form 10/A, Amendment No. 4 of Golden Growers Cooperative (the “Cooperative”). To facilitate your review of our response, we are including your comment in boldface type, followed by our response.
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 the fiscal years 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 disclosing such restatement or tell us why you believe such filing is not required.
RESPONSE:
Per your request above, on the date hereof the Cooperative filed an Item 4.02 Form 8-K discussing the circumstances related to its restatement of its various financial statements.
* * *
112 Roberts Street North. Suite 111, Fargo, ND 58102
We believe our response contained above addresses your current concern. As previously indicated, we are in the process of preparing our financial statements for fiscal year 2010 as well as our first Annual Report on Form 10-K. We would like to complete our financial statements and file our periodic reports in a manner that reflects your final determination as to this matter so to the extent you have completed your review and have no further comments, please provide us with written confirmation that your review is final. Until we hear otherwise, we will proceed with preparing our filings on the basis set forth in our prior correspondence.
Please feel free to call me at (701) 281-0468 or our counsel, Kimberly Lowe at (612) 492-7324, if you require additional information or clarification of our responses. You may email any correspondence to me at mdillon@goldengrowers.com and to Ms. Lowe at klowe@fredlaw.com.
Very truly yours,
Mark Dillon
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CORRESP 1 filename1.htm March 1, 2011 VIA EDGAR CORRESPONDENCE AND FACSIMILE Mr. John Reynolds Assistant Director, Division of Corporation Finance Securities and Exchange Commission 100 F Street N.E., Mail Stop 3561 Washington, D.C. 20549-3561 Re: Golden Growers Cooperative Form 10, Amendment 4 Filed December 20, 2010 File No. 0-53957 Dear Mr. Reynolds: We are writing in response to your letter dated February 25, 2011, regarding the Registration Statement as amended on Form 10/A, Amendment No. 4 of Golden Growers Cooperative (the “Cooperative”). To facilitate your review of our response, we are including your comment in boldface type, followed by our response. 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 the fiscal years 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 disclosing such restatement or tell us why you believe such filing is not required. RESPONSE: Per your request above, on the date hereof the Cooperative filed an Item 4.02 Form 8-K discussing the circumstances related to its restatement of its various financial statements. * * * 112 Roberts Street North. Suite 111, Fargo, ND 58102 We believe our response contained above addresses your current concern. As previously indicated, we are in the process of preparing our financial statements for fiscal year 2010 as well as our first Annual Report on Form 10-K. We would like to complete our financial statements and file our periodic reports in a manner that reflects your final determination as to this matter so to the extent you have completed your review and have no further comments, please provide us with written confirmation that your review is final. Until we hear otherwise, we will proceed with preparing our filings on the basis set forth in our prior correspondence. Please feel free to call me at (701) 281-0468 or our counsel, Kimberly Lowe at (612) 492-7324, if you require additional information or clarification of our responses. You may email any correspondence to me at mdillon@goldengrowers.com and to Ms. Lowe at klowe@fredlaw.com. Very truly yours, Mark Dillon Executive Vice President cc: Kimberly A Lowe Daniel Mott 2