SEC Comment Letter for BLUE BIOFUELS, INC. (BIOF) (CIK 0001549145) (BIOF) — Sep 4, 2014
BLUE BIOFUELS, INC. (BIOF) (CIK 0001549145)
Date: Sept. 4, 2014 · CIK: 0001549145 · Accession: 0000000000-14-044346
AI Filing Summary & Sentiment
File numbers found in text: 000-54942
Letter
September 4 , 2014 Via E-Mail Mr. Daniel de Liege Chief Executive Officer Alliance Media Group Holdings, Inc. 400 North Congress Avenue Suite 130 West Palm Beach, FL 33401
Re: Alliance Media group Holdings, Inc. Form 10-K for the year ended December 31, 2013 Filed May 19, 2014 File No. 000-54942
Dear Mr. De Liege :
We have reviewed your letter dated August 5 , 2014 , in response to the Staff’s letter dated July 16 , 2014 and have the following additional comments. Please revise your disclosure in response to our comments. Your response should be submitted in electronic form, under the label “corresp” with a copy to the staff. Please respond within ten (10) business days.
Form 10 -K for the fiscal year ended December 31, 2013 Note 6 – Investment in Carbolosic
1. We note from the footnotes to your financial statements included in your Form 10 -Q for the period ended June 30, 2014 that you monitor investments in non -consolidated affiliates for impairment at least annually and make appropriate reductions in the carrying value if you determine that an impairment charge is required based on qualitative and quantitative information. In this regard, please tell us what consideration yo u have given to potential impairment of your investment in Carbolosic in light of the ongoing losses associated with this investment since acquisit ion, and explain why you believe the license for CTS technology is recoverable and has future economic value at June 30, 2014. Please provide us with your analysis which supports the basis for your conclusions. As part of your response, please include key assumptions used, your basis for those assumptions, and when it was performed. Please note that to the extent you have assumed certain future cash flows generated from this patent, please provide us with factual evidence that supports these assumptions, and if actual results have not matched assumptions explain why. If after further consideration, you determine that your investment is no longer recoverable, you should revise your financial statements accordingly. We may have further comment upon reviewing your response.
Mr. Daniel de Liege Alliance Media Group Holdings, Inc. September 4 , 2014 Page 2
You may contact Effie Simpson at (202) 551 -3346 , or in her ab sence, Jean Yu at (202) 551-3305 if you have questions regarding comments on the financial statements and related matters. Please contact the undersigned, at (202) 551 -3750 with any other questions.
Sincerely,
/s/ Linda Cvrkel
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September 4 , 2014
Via E-Mail
Mr. Daniel de Liege
Chief Executive Officer
Alliance Media Group Holdings, Inc.
400 North Congress Avenue
Suite 130
West Palm Beach, FL 33401
Re: Alliance Media group Holdings, Inc.
Form 10-K for the year ended December 31, 2013
Filed May 19, 2014
File No. 000-54942
Dear Mr. De Liege :
We have reviewed your letter dated August 5 , 2014 , in response to the Staff’s letter dated
July 16 , 2014 and have the following additional comments. Please revise your disclosure in
response to our comments. Your response should be submitted in electronic form, under the label
“corresp” with a copy to the staff. Please respond within ten (10) business days.
Form 10 -K for the fiscal year ended December 31, 2013
Note 6 – Investment in Carbolosic
1. We note from the footnotes to your financial statements included in your Form 10 -Q for
the period ended June 30, 2014 that you monitor investments in non -consolidated
affiliates for impairment at least annually and make appropriate reductions in the carrying
value if you determine that an impairment charge is required based on qualitative and
quantitative information. In this regard, please tell us what consideration yo u have given
to potential impairment of your investment in Carbolosic in light of the ongoing losses
associated with this investment since acquisit ion, and explain why you believe the license
for CTS technology is recoverable and has future economic value at June 30, 2014.
Please provide us with your analysis which supports the basis for your conclusions. As
part of your response, please include key assumptions used, your basis for those
assumptions, and when it was performed. Please note that to the extent you have
assumed certain future cash flows generated from this patent, please provide us with
factual evidence that supports these assumptions, and if actual results have not matched
assumptions explain why. If after further consideration, you determine that your
investment is no longer recoverable, you should revise your financial statements
accordingly. We may have further comment upon reviewing your response.
Mr. Daniel de Liege
Alliance Media Group Holdings, Inc.
September 4 , 2014
Page 2
You may contact Effie Simpson at (202) 551 -3346 , or in her ab sence, Jean Yu at (202)
551-3305 if you have questions regarding comments on the financial statements and related
matters. Please contact the undersigned, at (202) 551 -3750 with any other questions.
Sincerely,
/s/ Linda Cvrkel
Linda Cvrkel
Branch Chief