SEC Company Response from 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: 0001615774-18-006695
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File numbers found in text: 333-226001
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CORRESP
1
filename1.htm
Greenland Acquisition Corporation
Suite 906, Tower W1, Oriental Plaza,
No. 1 East Chang’an Street
Dongcheng District, Beijing
People’s Republic of China
Division of Corporation Finance
Office of Transportation and Leisure
U.S. Securities & Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attn: Tonya K. Aldave
July 19, 2018
Re: Greenland Acquisition Corporation
Amendment No. 1 to Registration
Statement on Form S-1
Filed July 16, 2018
File No.
333-226001
Dear Ms. Aldave:
On behalf of Greenland Acquisition Corporation,
a British Virgin Islands company (the “Company”), we hereby transmit the Company’s response to the comment letter
received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”),
on July 19, 2018, regarding the Amendment No. 1 to Registration Statement on Form S-1 submitted to the Commission on July 16, 2018.
For the Staff’s convenience, we have
repeated below the Staff’s comments in bold, and have followed each comment with the Company’s response.
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.
We have revised exhibit 10.7 to remove the
arbitration provision.
We thank the Staff
for its review of the foregoing. If you have further comments, we ask that you forward them by electronic mail to our counsel,
Stuart Neuhauser at sneuhauser@egsllp.com or by telephone at (212) 370-1300.
Sincerely,
/s/
Yanming
Liu
Yanming
Liu