SEC Comment Letter for MARA Holdings, (MARA) — Oct 29, 2014
MARA Holdings, Inc.
Date: Oct. 29, 2014 · CIK: 0001507605 · Accession: 0000000000-14-053782
AI Filing Summary & Sentiment
Referenced dates: October 8, 2014
Letter
October 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 October 1 4, 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 informatio n, 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 response.
After reviewing any amendme nt 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 October 8, 2014 .
Form 10 -Q for the Qu arterly Period Ended June 30, 2014
Item 1. Financial Statements
Consolidated Statements of Operations, page 3
1. We note your response to prior comment 1. We continue to believe that the nature of patent amortization expense represents a cost of revenue . In this regard, we note that several companies in the industry, including some of the companies included your analysis of peer companies, properly reflect su ch expense as a cost of revenue , which is dissimilar to you r presentation. Additionally, w e also not e that several of the companies included in your analysis that do not present such costs as a cost of revenue have income statement presentations that are not similar to your presentation. Please revise your
Francis Knuettel II Marathon Patent Group, Inc. October 29, 2014 Page 2
presentation to classify patent amortization expense as a cost of revenue or tell us why such classification is not necessary.
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 f urther assistance, do not hesitate to contact me at (202) 551 -3406 .
Sincerely,
/s/ Patrick Gilmore
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October 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 October 1 4, 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 informatio n, 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 response. After reviewing any amendme nt 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 October 8, 2014 . Form 10 -Q for the Qu arterly Period Ended June 30, 2014 Item 1. Financial Statements Consolidated Statements of Operations, page 3 1. We note your response to prior comment 1. We continue to believe that the nature of patent amortization expense represents a cost of revenue . In this regard, we note that several companies in the industry, including some of the companies included your analysis of peer companies, properly reflect su ch expense as a cost of revenue , which is dissimilar to you r presentation. Additionally, w e also not e that several of the companies included in your analysis that do not present such costs as a cost of revenue have income statement presentations that are not similar to your presentation. Please revise your Francis Knuettel II Marathon Patent Group, Inc. October 29, 2014 Page 2 presentation to classify patent amortization expense as a cost of revenue or tell us why such classification is not necessary. 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 f urther assistance, do not hesitate to contact me at (202) 551 -3406 . Sincerely, /s/ Patrick Gilmore Patrick Gilmore Accounting Branch Chief