SEC Comment Letter 0000000000-23-013580 to MULIANG VIAGOO TECHNOLOGY, INC. (MULG) (CIK 0001629665)
MULIANG VIAGOO TECHNOLOGY, INC. (MULG) (CIK 0001629665)
Date: Dec. 13, 2023 · CIK: 0001629665 · Accession: 0000000000-23-013580
AI Filing Summary & Sentiment
File numbers found in text: 001-40636
Letter
United States securities and exchange commission logo December 13, 2023 Lirong Wang Chief Executive Officer Muliang Viagoo Technology, Inc. 2498 Wanfeng Highway, Lane 181 Fengjing Town, Jinshan District Shanghai, China Re:Muliang Viagoo Technology, Inc. Amendment No. 1 to Form 10-K for the fiscal year ended December 31, 2022 Filed July 6, 2023 File No. 001-40636 Dear Lirong Wang: We have reviewed your filing and have the following comment(s). Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Amendment No. 1o to Form 10-K for the fiscal year ended December 31, 2022 Contractual Arrangements, page 7 1.We note your response to comment 6, and your revised disclosure referencing the names of the relevant agreements that you have entered into pursuant to your VIE structure. Please revise your disclosure in this section to provide a brief description of each of these agreements. Executive Compensation, page 93 2.As previously requested, it appears that the financial statements may need to be revised to account for the services provided by your CEO and CFO at fair value. In this regard, it does not appear that the compensation expense included in your 2021 and 2021 financial statements comprises a reasonable estimate of the fair value of the services provided by your CEO and CFO. Please refer to the guidance in SAB 1:B.
FirstName LastNameLirong Wang Comapany NameMuliang Viagoo Technology, Inc. December 13, 2023 Page 2 FirstName LastName Lirong Wang Muliang Viagoo Technology, Inc. December 13, 2023 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355 if you have questions regarding comments on the financial statements and related matters. Please contact Conlon Danberg at 202-551-4466 or Katherine Bagley at 202-551-2545 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc: Jason Ye, Esq.
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United States securities and exchange commission logo
December 13, 2023
Lirong Wang
Chief Executive Officer
Muliang Viagoo Technology, Inc.
2498 Wanfeng Highway, Lane 181
Fengjing Town, Jinshan District
Shanghai, China
Re:Muliang Viagoo Technology, Inc.
Amendment No. 1 to Form 10-K for the fiscal year ended December 31, 2022
Filed July 6, 2023
File No. 001-40636
Dear Lirong Wang:
We have reviewed your filing and have the following comment(s).
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Amendment No. 1o to Form 10-K for the fiscal year ended December 31, 2022
Contractual Arrangements, page 7
1.We note your response to comment 6, and your revised disclosure referencing the names
of the relevant agreements that you have entered into pursuant to your VIE structure.
Please revise your disclosure in this section to provide a brief description of each of these
agreements.
Executive Compensation, page 93
2.As previously requested, it appears that the financial statements may need to be revised to
account for the services provided by your CEO and CFO at fair value. In this regard, it
does not appear that the compensation expense included in your 2021 and 2021 financial
statements comprises a reasonable estimate of the fair value of the services provided by
your CEO and CFO. Please refer to the guidance in SAB 1:B.
FirstName LastNameLirong Wang
Comapany NameMuliang Viagoo Technology, Inc.
December 13, 2023 Page 2
FirstName LastName
Lirong Wang
Muliang Viagoo Technology, Inc.
December 13, 2023
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Please contact Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355 if you have
questions regarding comments on the financial statements and related matters. Please contact
Conlon Danberg at 202-551-4466 or Katherine Bagley at 202-551-2545 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc: Jason Ye, Esq.