SEC Comment Letter for Bit Digital, Inc (BTBT) (CIK 0001710350) (BTBT) — Sep 26, 2019
Bit Digital, Inc (BTBT) (CIK 0001710350)
Date: Sept. 26, 2019 · CIK: 0001710350 · Accession: 0000000000-19-013976
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38421
Letter
September 25, 2019 Erxin Zeng Chief Executive Officer Golden Bull Ltd 707 Zhang Yang Road Sino Life Tower, F35 Pudong, Shanghai, China 200120 Re:Golden Bull Ltd Form 20-F for Fiscal Year Ended December 31, 2018 Response dated August 30, 2019 File No. 001-38421 Dear Mr. Zeng: We have reviewed your August 30, 2019 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 30, 2019 letter. Form 20-F for Fiscal Year Ended December 31, 2018 Note 7 - Taxes, page F-19 1.We note your response and corresponding Exhibits provided in response to comment 2. As noted in your revised forecast in Exhibit C, due to the increasingly stricter regulations of the P2P industry by the Chinese government you now forecast losses in all future periods. Based on your historical losses and your revised forecast of projected losses, please recognize a valuation allowance on your deferred tax asset or tell us further how and why you have determined that a valuation allowance is not appropriate.
FirstName LastNameErxin Zeng Comapany NameGolden Bull Ltd September 25, 2019 Page 2 FirstName LastName Erxin Zeng Golden Bull Ltd September 25, 2019 Page 2 You may contact John Spitz, Staff Accountant, at (202) 551-3484 or Michael Volley, Staff Accountant, at (202) 551-3437 with any questions. Sincerely, Division of Corporation Finance Office of Financial Services cc: Jing Leng
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September 25, 2019
Erxin Zeng
Chief Executive Officer
Golden Bull Ltd
707 Zhang Yang Road
Sino Life Tower, F35
Pudong, Shanghai, China 200120
Re:Golden Bull Ltd
Form 20-F for Fiscal Year Ended December 31, 2018
Response dated August 30, 2019
File No. 001-38421
Dear Mr. Zeng:
We have reviewed your August 30, 2019 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in
our August 30, 2019 letter.
Form 20-F for Fiscal Year Ended December 31, 2018
Note 7 - Taxes, page F-19
1.We note your response and corresponding Exhibits provided in response to comment 2.
As noted in your revised forecast in Exhibit C, due to the increasingly stricter regulations
of the P2P industry by the Chinese government you now forecast losses in all future
periods. Based on your historical losses and your revised forecast of projected losses,
please recognize a valuation allowance on your deferred tax asset or tell us further how
and why you have determined that a valuation allowance is not appropriate.
FirstName LastNameErxin Zeng
Comapany NameGolden Bull Ltd
September 25, 2019 Page 2
FirstName LastName
Erxin Zeng
Golden Bull Ltd
September 25, 2019
Page 2
You may contact John Spitz, Staff Accountant, at (202) 551-3484 or Michael Volley,
Staff Accountant, at (202) 551-3437 with any questions.
Sincerely,
Division of Corporation Finance
Office of Financial Services
cc: Jing Leng