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United States securities and exchange commission logo
August 25, 2023
Bob Loughran
Chief Financial Officer
Greenidge Generation Holdings Inc.
135 Rennell Drive, 3rd Floor
Fairfield, CT 06890
Re: Greenidge
Generation Holdings Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2022
Filed March 31,
2023
Form 10-Q for the
Period ending March 31, 2023
Filed May 15, 2023
File No. 001-40808
Dear Bob Loughran:
We have reviewed your August 3, 2023 response to our comment
letter 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 these comments 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
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. Unless we note otherwise, our references to prior comments are
to comments in our
July 6, 2023 letter.
Form 10-K for the Years Ended December 31, 2022 and 2021
Consolidated Statements of Cash Flows, page F-6
1. We note your response
to prior comment 4, specifically your assertion that you "generally
convert the
cryptocurrency earned into U.S. dollars in a relatively short period of time."
We also note from your
response to prior comment 7 that 1) you receive your
compensation in the
form of bitcoin the day following the one-day contract and or one day
from the date earned,
2) the significant majority of crypto currency received (bitcoin)
from pool operators is
sold within minutes of receipt and 3) that the remaining bitcoin
received from pool
operators is liquidated utilizing a standard bitcoin reference price from
the day subsequent to
the date earned. Please address the following:
Bob Loughran
Greenidge Generation Holdings Inc.
August 25, 2023
Page 2
Confirm to us and clarify in future filings that all
crytocurrency earned is received the
day following the one-day contract and or one day from when it is
earned;
For cryptocurrency received from mining not sold within minutes
of receipt, confirm
the remaining crytocurrency received is sold within one day of
receipt and or one day
from earned;
Tell us if you have a set time daily for which the remaining
crytocurrency is sold and
your average holding period for the periods presented; and
Confirm that you only receive crytocurrency revenue from your
mining pool
operations.
Notes to Consolidated Financial Statements
Summary of Significant Accounting Policies, page F-7
2. We note your response to prior comment 9 and your determination of
CoinMarketCap as
your principal market for valuing your digital assets. As
CoinMarketCap is not a market
where digital assets can be traded but instead is a website where
exchange/trading
platform market information is aggregated, its aggregated information
cannot be the
principal market, or most advantageous market in the absence of a
principal market, under
ASC 820-10-35-5. As CoinMarketCap also separately displays pricing
information from
individual exchanges/trading platforms, please tell us whether one of
the individual
exchanges/trading platforms displayed on CoinMarketCap is your
principal or most
advantageous market. If so revise your disclosure to identify this
specific market. If not,
revise your accounting and disclosure to identify the single
exchange/trading platform that
is your principal or most advantageous market for each digital asset
you hold or held.
Regardless, tell us how you identified these single markets for each
digital asset as your
principal or most advantageous markets and reference the for us the
authoritative literature
you relied upon to support your position.
You may contact Dave Irving at 202-551-3321 or Michelle Miller at
202-551-3368 if you
have questions.
FirstName LastNameBob Loughran Sincerely,
Comapany NameGreenidge Generation Holdings Inc.
Division of
Corporation Finance
August 25, 2023 Page 2 Office of
Crypto Assets
FirstName LastName