SEC Comment Letter for Penguin Solutions, Inc. (PENG) (CIK 0001616533) (PENG) — Feb 20, 2015
Penguin Solutions, Inc. (PENG) (CIK 0001616533)
Date: Feb. 20, 2015 · CIK: 0001616533 · Accession: 0000000000-15-010745
AI Filing Summary & Sentiment
Reasoning
Letter
February 20, 2015 Via E -mail Bruce Goldberg Vice President, Chief Legal Officer and Chief Compliance Officer SMART Global Holdings, Inc. 39870 Eureka Drive Newark, CA 94560
Re: SMART Global Holdings, Inc. Amendment No. 2 to Draft Registration Statement on Form S -1 Submitted February 5, 201 5 CIK No. 0001 616533
Dear Mr. Goldberg :
We have reviewed your amended draft registration statement and have the following comment . Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comment appl ies to your facts and circums tances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to the comment and your amended draft registration statement or filed registration statement, we may have additional comments.
Consolidated Balance Sheets, page F -3
1. We note the inclusion of a column for the interim balance sheet as of November 28, 2014 which is unaudited. However, it appears that the audited balance sheet as of August 29, 2014 has been err oneously labeled as “unaudited .” Please revise the statement to correct the placement of this label.
Bruce Goldberg SMART Global Holdings, Inc. February 20, 2015 Page 2
You may contact David Burton at (202) 551 -3626 or Kate Tillan, Assistant Chief Accountant, at (202) 551 -3604 if you have questions regarding comments on the financial statements and related matters. Please contact Tom Jones at (202) 551 -3602 or Mary Beth Breslin, Senior Attorney, at (202) 551 -3625 with any other questions.
Sincerely,
/s/ Mary Beth Breslin for
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February 20, 2015 Via E -mail Bruce Goldberg Vice President, Chief Legal Officer and Chief Compliance Officer SMART Global Holdings, Inc. 39870 Eureka Drive Newark, CA 94560 Re: SMART Global Holdings, Inc. Amendment No. 2 to Draft Registration Statement on Form S -1 Submitted February 5, 201 5 CIK No. 0001 616533 Dear Mr. Goldberg : We have reviewed your amended draft registration statement and have the following comment . Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comment appl ies to your facts and circums tances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to the comment and your amended draft registration statement or filed registration statement, we may have additional comments. Consolidated Balance Sheets, page F -3 1. We note the inclusion of a column for the interim balance sheet as of November 28, 2014 which is unaudited. However, it appears that the audited balance sheet as of August 29, 2014 has been err oneously labeled as “unaudited .” Please revise the statement to correct the placement of this label. Bruce Goldberg SMART Global Holdings, Inc. February 20, 2015 Page 2 You may contact David Burton at (202) 551 -3626 or Kate Tillan, Assistant Chief Accountant, at (202) 551 -3604 if you have questions regarding comments on the financial statements and related matters. Please contact Tom Jones at (202) 551 -3602 or Mary Beth Breslin, Senior Attorney, at (202) 551 -3625 with any other questions. Sincerely, /s/ Mary Beth Breslin for Amanda Ravitz Assistant Director cc (via e -mail): Alan F. Denenberg