SEC Comment Letter for MARA Holdings, (MARA) — Sep 29, 2014
MARA Holdings, Inc.
Date: Sept. 29, 2014 · CIK: 0001507605 · Accession: 0000000000-14-048765
AI Filing Summary & Sentiment
Referenced dates: August 14, 2014, September 12, 2014
Letter
September 29, 2014 Via E -mail Francis Knuettel II Chief Financial Officer Marathon Patent Group, Inc. 11100 Santa Monica Blvd., Ste. 380 Los Angeles, CA 90025
Re: Marathon Patent Group, Inc. Form 10-Q for the Quarterly Period Ended June 30, 2014 Filed August 14, 2014 File No. 00 1-36555
Dear Mr. Knuettel :
We have reviewed your letter dated September 12, 2014 in connection with the above - referenced filing an d have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your respon se.
After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments. Unless otherwise noted , where prior comments are referred to they refer to our letter dated August 14, 2014 .
Form 10 -Q for the Quarterly Period Ended June 30, 2014
Item 1. Financial Statements
Consolidated Statements of Operations, page 3
1. We note that you have classified patent amortization expense as a separate operating expense line item outside of cost of revenues . Please tell us what co nsideration was given to including this expense within cost of revenues considering your patent portfolio appear s to be related to revenue generating activities. Refer to Rule 5 -03(b)(2) of Regulation S -X.
Francis Knuettel II Marathon Patent Group, Inc. September 29, 2014 Page 2
You may contact David Edgar, Staff Accountant , at (202) 551 -3459 if you have questions regarding comments on the financial statements and re lated matters. If you require further assistance, do not hesitate to contact me at (202) 551 -3406 .
Sincerely,
/s/ Patrick Gilmore
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September 29, 2014 Via E -mail Francis Knuettel II Chief Financial Officer Marathon Patent Group, Inc. 11100 Santa Monica Blvd., Ste. 380 Los Angeles, CA 90025 Re: Marathon Patent Group, Inc. Form 10-Q for the Quarterly Period Ended June 30, 2014 Filed August 14, 2014 File No. 00 1-36555 Dear Mr. Knuettel : We have reviewed your letter dated September 12, 2014 in connection with the above - referenced filing an d have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your respon se. After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments. Unless otherwise noted , where prior comments are referred to they refer to our letter dated August 14, 2014 . Form 10 -Q for the Quarterly Period Ended June 30, 2014 Item 1. Financial Statements Consolidated Statements of Operations, page 3 1. We note that you have classified patent amortization expense as a separate operating expense line item outside of cost of revenues . Please tell us what co nsideration was given to including this expense within cost of revenues considering your patent portfolio appear s to be related to revenue generating activities. Refer to Rule 5 -03(b)(2) of Regulation S -X. Francis Knuettel II Marathon Patent Group, Inc. September 29, 2014 Page 2 You may contact David Edgar, Staff Accountant , at (202) 551 -3459 if you have questions regarding comments on the financial statements and re lated matters. If you require further assistance, do not hesitate to contact me at (202) 551 -3406 . Sincerely, /s/ Patrick Gilmore Patrick Gilmore Accounting Branch Chief