SEC Comment Letter for Pangaea Logistics Solutions Ltd. (PANL) (CIK 0001606909) (PANL) — Jan 17, 2020
Pangaea Logistics Solutions Ltd. (PANL) (CIK 0001606909)
Date: Jan. 17, 2020 · CIK: 0001606909 · Accession: 0000000000-20-000457
AI Filing Summary & Sentiment
Letter
January 17, 2020 Edward Coll Chief Executive Officer Pangaea Logistics Solutions, Ltd. c/o Phoenix Bulk Carriers (US) LLC 109 Long Wharf Newport, RI 02840 Re:Pangaea Logistics Solutions Ltd. Form 10-K for Fiscal Year Ended December 31, 2018 Filed March 20, 2019 Response Dated January 3, 2020 File No. 1-36798 Dear Mr. Coll: We have reviewed your January 3, 2020 response to our comment letter 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. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 4, 2019 letter. Form 10-K for Fiscal Year Ended December 31, 2018 Item 6. Selected Financial Data Selected Data from the Consolidated Statements of Operations, page 39 1.We note your response to comment 2. In your proposed revised disclosure, you reconcile gross profit to net transportation and service revenue, a non-GAAP measure. Since you do not present or define gross profit elsewhere in your filing, please tell us and disclose how you calculate gross profit. 2.Please revise to disclose income/(loss) from continuing operations per common share and cash dividends declared per common share within Selected Financial Data. Refer to Instruction 2 of the Instructions to Item 301 of Regulation S-K.
FirstName LastNameEdward Coll Comapany NamePangaea Logistics Solutions, Ltd. January 17, 2020 Page 2 FirstName LastName Edward Coll Pangaea Logistics Solutions, Ltd. January 17, 2020 Page 2 You may contact Yolanda Guobadia, Senior Staff Accountant, at (202) 551-3562 or Sondra Snyder, Senior Staff Accountant, at (202) 551-3332 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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January 17, 2020
Edward Coll
Chief Executive Officer
Pangaea Logistics Solutions, Ltd.
c/o Phoenix Bulk Carriers (US) LLC
109 Long Wharf
Newport, RI 02840
Re:Pangaea Logistics Solutions Ltd.
Form 10-K for Fiscal Year Ended December 31, 2018
Filed March 20, 2019
Response Dated January 3, 2020
File No. 1-36798
Dear Mr. Coll:
We have reviewed your January 3, 2020 response to our comment letter 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.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
December 4, 2019 letter.
Form 10-K for Fiscal Year Ended December 31, 2018
Item 6. Selected Financial Data
Selected Data from the Consolidated Statements of Operations, page 39
1.We note your response to comment 2. In your proposed revised disclosure, you reconcile
gross profit to net transportation and service revenue, a non-GAAP measure. Since you
do not present or define gross profit elsewhere in your filing, please tell us and disclose
how you calculate gross profit.
2.Please revise to disclose income/(loss) from continuing operations per common share and
cash dividends declared per common share within Selected Financial Data. Refer to
Instruction 2 of the Instructions to Item 301 of Regulation S-K.
FirstName LastNameEdward Coll
Comapany NamePangaea Logistics Solutions, Ltd.
January 17, 2020 Page 2
FirstName LastName
Edward Coll
Pangaea Logistics Solutions, Ltd.
January 17, 2020
Page 2
You may contact Yolanda Guobadia, Senior Staff Accountant, at (202) 551-3562 or
Sondra Snyder, Senior Staff Accountant, at (202) 551-3332 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation