SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4631
       DIVISION OF
CORPORATION FINANCE

 Mail Stop 4631

December 29, 2017

Via E-Mail
Mr. Tim Richerson
Chief Executive Officer
JM Global Holding Company
1615 South Congress Avenue, Suite 103
Delray Beach, FL  33445

 Re: JM Global Holding Company
  Revised Preliminary Merger Proxy Statement on Schedule 14A
  Filed December 20, 2017
 File No. 1 -37513

Dear Mr. Richerson :

We have reviewed the  filing and have the following comments.  In some of  our
comments  we may ask you to provide  information so that we may better understand your
disclosure.

Please respond to these comments within 10 business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not bel ieve that
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.

Amendment No. 2 to the Preliminary Proxy Statement filed December 20, 2017

Sunlong Management’s Discussion and Analysis, page 156

Results of Operations, page 157

1. You state on page 159: "Our trading of industrial waste materials are dependent to the
progress of the end users whom used our solid waste recycling equipment and when they
are able to sell those industrial waste materials to our suppliers to process the w aste."
Please clarify this sentence given it appears that China Sunlong's suppliers sell waste

Mr. Tim Richerson
JM Global Holding Company
December 29 , 2017
Page 2

 materials to China Sunlong and then China Sunlong sells those waste materials to the two
significant business “end users” who are related to each other, but then  those end users
sell the waste materials back to the suppliers.  Assuming this sequence is correct, explain
to us why the two related end users do not instead purchase the waste materials directly
from the suppliers, since your suppliers directly drop ship  the waste materials to them.  In
this regard, it is not clear what value, if any, China Sunlong has provided to the related
end users and therefore how it has earned or appropriately recognized revenues.   It is also
not clear whether there is a legitimate b usiness purpose for the two related end users to
pay a 34% premium (equivalent to the gross margin recorded on these transactions
through September 30, 2017) to only process these transactions through China Sunlong.
Please disclose in the filing whether ma nagement believes that this trading business
model is sustainable and the basis for that assessment.

2. We have read the revision on page 161 related to the third bullet of comment 4 in our
letter dated December 14, 2017.  You have disclosed that you ear ned consulting revenue
during the year ended December 31, 2016 with “minimal cost” associated with that
revenue.  Please explain why or how such revenue was able to be recorded with “minimal
cost.”

Liquidity and Capital Resources, page 170

3. Regarding the latest revision to the accounts receivable discussion on page 170, the
responses provided in your letters raise a concern that China Sunlong’s September 30,
2017 allowance for doubtful accounts accounting policy was not applied in a complete
and object ive manner as required by ASC 310 -10-35-4 through 35 -11.  The responses
focus on unsupported and subjective assumptions while failing to fully address the
primary objective and verifiable evidence that was known when the September 30, 2017
financial stateme nts were filed on December 1, 2017.  For example, when the September
30, 2017 financial statements were filed, management knew that the two affiliated
customers that generated substantially all of your 2017 trading revenue had not paid any
of the $18.7 mill ion of receivables associated with those revenues, irrespective of the
applicable 30 day payment terms.  Further, management knew that approximately $11
million of that balance was over five months old and that the significant delinquency
cannot reasonably be attributed to the two customers’ longer “operating cycles” given
that these same customers were apparently able to pay substantially all of the $837,332
they owed on the July 1, 2016 – December 31, 2016 trading sales transactions by
December 31, 2016.  Also, management was aware that they had very little experience
negotiating these trading transactions prior to 2017.  We further note that despite our
prior request, management was not able to specifically explain why the customers have
not been able to pay  what they owe.  In addition, there does not appear to be any

Mr. Tim Richerson
JM Global Holding Company
December 29 , 2017
Page 3

 objective and verifiable evidence supporting an assumption that the two customers
currently have the financial resources to pay what they owe.  ASC 310 -10-35-8 requires
that management consider su ch known evidence that existed up through the date the
financial statements were actually issued.  Please revise the China Sunlong financial
statements to establish an allowance for doubtful accounts balance that reasonably
reflects the known, adverse and o bjective evidence surrounding the collectibility of these
receivables.  Alternatively, provide us with English translation versions of the underlying
contracts and a chronological summary of all discussions between China Sunlong and the
two customers concer ning the causes and status of these delinquent accounts so that we
can better understand whether there is a rational and objective basis for the zero
allowance balance at September 30, 2017.  In assessing the materiality of this issue, we
note that the deli nquent receivables approximate 30% of 2017 total assets and 50% of
2017 total revenue.  Further, we note that per page 93, the China Sunlong purchase that
shareholders are voting on was valued using a multiple of projected 2017 revenue.

4. On page F -54, it is reported that two customers accounted for 45.2% and 43.6% of the
September 30, 2017 receivables balance.   We understand that these two customers are in
fact related to each other.  Please revise Note 11 to disclose whether any of the referenced
custome rs and suppliers are related and disclose the nature of the relationships.  In
addition, please clarify whether any of the $14.8 million of trading business prepayments
(page 171) were paid to entities that are in any way related to the two customers that h ave
been unable to pay their $18.7 million of receivables.   If so, then please explain why no
September 30, 2017 loss allowance was reserved against this asset.

5. Please tell us whether the two major customers, Wuhan KYX and Wuhan Zhirong (page
34), are  either directly or indirectly owned or controlled by the people/entities that own or
control the major supplier, Wuhan Jingxin Photovoltaics New Energy Technology Co.,
Ltd (page 36).  Address also any relationship between these entities and Wuhan Mingjia
Industry and Trade Development Co. Ltd. since page 192 reports that Ms. Li controlled
both Wuhan and China Sunlong.  Describe also any family or contractual relationships
between Ms. Li and Mr. Wensheng Yan.   If China Sunlong’s major customers are
controlled by the same parties that control their major supplier, then clarify for us how
China Sunlong has any substantive control over the pricing in transactions involving
those companies.  Specifically, it would appear that the person/entity that controls both
the supplier and the customer could dictate any pricing terms as well as any associated
accounts receivable payment provisions.   Absent a legitimate ability to establish selling
prices, it would appear that the trading transactions described on page 159 should  be
recognized on a net basis instead of on a gross basis.

Mr. Tim Richerson
JM Global Holding Company
December 29 , 2017
Page 4

 You may direct questions on comments on the financial statements and related matters to
Jenn Do, Staff Accountant, at (202) 551 -3743 or Alfred P. Pavot, Jr., Staff Accountant, at (202)
551-3738.  You may direct questions on other comments and disclosure issues to Edward M.
Kelly, Senior Counsel, at (202) 551-3728 or me at (202) 551 -3765  with any  questions.

Very truly yours,

/s/ John Cash, for

Pamela A. Long
Assistant Director
Office of Manufacturing and
Construction

cc: Via E-Mail
 Douglas Ellenoff , Esq.
 Stuart Neuhauser, Esq.
 Ellenoff Grossman & Schole LLP
 1345 Avenue of the Americas, 11th Floor
 New York, NY 10105