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United States securities and exchange commission logo
April 23, 2024
Christian Mulvihill
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, 2023
File No. 001-40808
Dear Christian Mulvihill:
We have reviewed your February 29, 2024 response to our comment
letter and have the
following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our December 19, 2023
letter.
Form 10-K for the Fiscal Year Ended December 31, 2023
Significant Accounting Policies
Cryptocurrency Mining Revenue, page F-14
1. We note your response
to prior comment 2 and your revised cryptocurrency mining
revenue policy
disclosure on page F-14. In your revised disclosure you state that you are
entitled to
compensation even if the pool operator is unsuccessful in placing a block.
However, your
disclosure also implies you receive a share of the rewards paid to the pool
operator for successful
efforts. Please revise your disclosure in future filings to reconcile
the two statements and
clearly state that as a participant in an FPPS mining pool your
compensation is not
contingent on the pool operator successfully placing a block.
2. We note your response
to the third bullet in prior comment 2, that you consider each
mining pool arrangement
to be a contract that is continuously renewed, that the duration
of each contract is 24
hours or less and provides the same rate of payment upon renewal
Christian Mulvihill
Greenidge Generation Holdings Inc.
April 23, 2024
Page 2
and that since the pricing remains the same upon contract renewal, the
contract does not
provide the applicable mining pool operator with a material right that
represents a separate
performance obligation. Please enhance your cryptocurrency mining
revenue policy to
disclose in future filings.
Please contact David Irving at 202-551-3321 or Michelle Miller at
202-551-3368 if you
have questions regarding comments on the financial statements and related
matters.
FirstName LastNameChristian Mulvihill Sincerely,
Comapany NameGreenidge Generation Holdings Inc.
Division of
Corporation Finance
April 23, 2024 Page 2 Office of Crypto
Assets
FirstName LastName