SEC Comment Letter for Greenland Technologies Holding Corp. (GTEC) (CIK 0001735041) (GTEC) — Jul 19, 2018
Greenland Technologies Holding Corp. (GTEC) (CIK 0001735041)
Date: July 19, 2018 · CIK: 0001735041 · Accession: 0000000000-18-022193
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-226001
Letter
July 19, 2018 Yanming Liu Chief Executive Officer Greenland Acquisition Corp. Suite 906, Tower W1, Oriental Plaza, No. 1 East Chang'an Street Dongcheng District, Beijing People’s Republic of China Re:Greenland Acquisition Corporation Amendment No. 1 to Registration Statement on Form S-1 Filed July 16, 2018 File No. 333-226001 Dear Mr. Liu: We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Registration Statement on Form S-1 Exhibits 1.We note that the registration rights agreement filed as Exhibit 10.7 includes an arbitration provision. Please tell us whether such provision applies to claims under the federal securities laws.
FirstName LastNameYanming Liu Comapany NameGreenland Acquisition Corp. July 19, 2018 Page 2 FirstName LastName Yanming Liu Greenland Acquisition Corp. July 19, 2018 Page 2 You may contact Aamira Chaudhry at (202) 551-3389 or Doug Jones at (202) 551- 3309 if you have questions regarding comments on the financial statements and related matters. Please contact Tonya K. Aldave at (202) 551-3601 or Laura Nicholson, Special Counsel, at (202) 551-3584 with any other questions. Division of Corporation Finance Office of Transportation and Leisure cc: Stuart Neuhauser, Esq.
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July 19, 2018
Yanming Liu
Chief Executive Officer
Greenland Acquisition Corp.
Suite 906, Tower W1, Oriental Plaza, No. 1 East Chang'an Street
Dongcheng District, Beijing
People’s Republic of China
Re:Greenland Acquisition Corporation
Amendment No. 1 to Registration Statement on Form S-1
Filed July 16, 2018
File No. 333-226001
Dear Mr. Liu:
We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-1
Exhibits
1.We note that the registration rights agreement filed as Exhibit 10.7 includes an arbitration
provision. Please tell us whether such provision applies to claims under the federal
securities laws.
FirstName LastNameYanming Liu
Comapany NameGreenland Acquisition Corp.
July 19, 2018 Page 2
FirstName LastName
Yanming Liu
Greenland Acquisition Corp.
July 19, 2018
Page 2
You may contact Aamira Chaudhry at (202) 551-3389 or Doug Jones at (202) 551-
3309 if you have questions regarding comments on the financial statements and related
matters. Please contact Tonya K. Aldave at (202) 551-3601 or Laura Nicholson, Special
Counsel, at (202) 551-3584 with any other questions.
Division of Corporation Finance
Office of Transportation and Leisure
cc: Stuart Neuhauser, Esq.