Revenue recognition (ASC 606)

The Company respectfully acknowledges the Staff’s comment and confirms that the security transactions meet the criteria described in FASB ASC 946-320-25-2.

The Company acknowledges the staff’s comment and revised the game publishing revenue recognition disclosure as follows: The Company generates its revenue from game publishing by publishing gaming software on the third-party gaming platforms such as Sony's PlayStation Network and Valve's Steam (“Gaming Platform”). In this sales arrangement, the Gaming Platforms are considered as the Company's customers. The Company recognizes revenue from game publishing at the point in time when control of the gaming software is transferred to the Gaming Platform, which specifically occurs when the console game code has been activated. Since the transaction price varies and is determined based on a predetermined rate applied to the Gaming Platform’s monthly sales, the Company recognizes revenue based on the consideration expected to be received from the Gaming Platform.

The Company acknowledges the staff’s comment and confirms that the Company only generates game publishing revenue through Microsoft’s Xbox, Sony's Playstation Network and Valve's Steam platform, and does not participate in any other third-party platforms for game publishing.

The Company respectfully acknowledges the staff’s comment. The Company respectfully advises the staff that the publishing agreements mentioned above are with the third party game developers and provides the following explanation: The agreement with the Company’s existing developer only includes terms such as minimum sales guarantees and development fees, marketing budgets and localization. Disclosure on page 162 has been revised accordingly. The Company provides further explanation to the foregoing terms as follows: Minimum sales guarantee Pursuant to the agreement with the developer, the Company is obligated to pay several tranches of non-refundable minimum sales guarantee to the developer upon achievement of various milestones before the game is published on the gaming platform. Consequently, the Company records the minimum sales guarantee payment remitted to the developer as prepaid…

We respectfully acknowledge the Staff’s comment and advise the Staff that we will remove leasing revenue from the “Revenues from contracts with customers” table in our subsequent periodic filings, in accordance with ASC 606-10-50- 4(a). In addition, we advise the Staff that we will remove leasing balances from the “Contract Balances” table in subsequent periodic filings, in accordance with ASC 606-10-50-8. For the Staff’s reference, updated disclosure marked to show changes against the disclosure on page 70 of the Form 10-K is attached hereto as Exhibit A as an example, for illustrative purposes only, of how the Company intends to revise its disclosures in our subsequent periodic filings beginning with the Company’s Form 10-Q for the second quarter ending on June 30, 2024. Note 9. Restructuring and other charges, page 71

The performance obligations that costs in excess of billings relate to are the Company’s obligations to construct an asset that the customer controls as it is being created or enhanced, or a promise to provide a product that has no alternative use to the Company and for which the Company has enforceable rights to payment. United States Securities and Exchange Commission June 24, 2024 Page 3 In preparing the Company’s consolidated balance sheet and notes to the consolidated financial statements, we considered ASC 606-10-45-1 and 45-4 and determined that the related right to this consideration is conditioned on something other than the passage of time. We respectfully advise the Staff that in the Company’s Notes to the Consolidated Financial Statements - (3) Revenue in the Annual Report on Form 10-K for the year ended December 31, 2023 (the “10-K”), the Company discloses that its contract…

We have two types of introductory offers that we offer to customers. One is a “send no money” where the customer completes an application form; when the application is approved and the first month’s premium is received, the policy is in effect. The second introductory offer is up to one month of coverage for a reduced premium of $1. We record revenue at the time the premium is due, and the policy is issued in both types of introductory offers. The impact of the introductory offer period is not material to the Company’s consolidated financial statements. We propose to include the following disclosure within MD&A in our next Form 10-Q filing: Net sales are calculated as annualized premium issued, net of cancellations in the first thirty days after issue, except in the case of Direct to Consumer, where net sales is annualized premium issued at the time the first full premium is paid after…

The Company acknowledges the Staff’s comment and has set forth below each item followed by the Company’s response. • Even if the 5.2 million non-unique users identified in your response were unique individual customers, that amount would represent only 22.2% of your 23.4 million Funded Customers at December 31, 2023. Tell us why it is appropriate to consider at least 18.2 million users (or at least 77.8% of your Funded Customers) as customers if they pay you no consideration for access to your platform or for other services.

10 This change did not impact (i) the Company’s accounting for the Robinhood Referral Program, which the Company determined provides it with a distinct service from users, and (ii) the accounting for fraud reimbursement payments under ASC 460, Guarantees , as explained below. 10 The Company respectfully advises the Staff that the analysis as to when the determination that all users met the definition of a customer is provided above. The analysis focuses on new product and features that required analysis under ASC 606 and is not inclusive of all new products and features the Company has introduced during the period as not all new product and features required analysis under ASC 606 (e.g., recurring crypto investments launched in September 2021 did not require analysis under ASC 606). The “would be” language used in the March Response Letter was tied to when that determination was made in…

SBC advises that the balance of advances from customers - related parties primarily included 1) the cash received in an amount equivalent to the awarded loyalty points that have not been redeemed by MCs' customers, which would be returned to MCs upon the redemption of the loyalty points or recognized as SBC's revenue when the points are expired, which has not been significant historically; and 2) MCs' overpayment for procurement services revenue when SBC received discounts on certain large purchases, which would be returned to MCs at a later time. Based on historical data, the majority of the balance of advances from customers - related parties represented cash that would be returned to MCs subsequently, instead of deferred revenue, therefore, the amount being recognized as revenues is much smaller than the total balance. Changes in response to the Staff’s comment have been reflected in…

We acknowledge the Staff's comment and respectfully advise the Staff that the Company recognized revenue of $183,000 and $683,000 during the years ended December 31, 2023 and 2022, respectively, related to one contract with an advertising performance guarantee. The guarantee provided the customer with a specified level of sales attainment per advertising dollar spent as reported by the customer. For this contract, we recognized revenue over time as the performance guarantee was achieved. Given that amounts were not material to either year (as they represented 0.02% of 2023 net revenue and 0.07% of 2022 net revenue), we did not specifically disclose the Company’s revenue recognition policy for this contract within our financial statement footnotes. In future filings, we will remove the reference to “advertising performance guarantees” in our financial statement footnotes if the…

The Company acknowledges the Staff’s comment and confirms that the Company acted as principal in all its arrangements for the periods presented. In connection with the restatement of the Company’s prior financial statements, the Company identified certain elements of its agreements with customers for development services that were recorded as if the Company was operating as an agent and thus was recorded on a net basis, which was corrected as part of the restatement of those prior periods reflected in the Filing. In future filings, the Company will expand its revenue recognition policy disclosures to state that the Company is the principal in its contracts and recognizes revenues on a gross basis, or, as may be relevant, net as an agent and the related disaggregated revenues, if any. Related Party Transactions, page 81

We acknowledge the Staff’s comment and note that extended warranty and service revenues as a percentage of Connected Fitness Products gross profit 1 are approximately (26)%, (16)%, and 2% and extended warranty and service revenues as a percentage of total gross profit are approximately 6%, 6%, and 1%, in each case for the fiscal years ending June 30, 2023, 2022, and 2021, respectively. We also note that the impact of removing extended warranty and services revenues from our gross profit would result in a decrease of approximately 6%, 2%, and less than 1% in our Connected Fitness Products gross profit percentage and a decrease of 1%, 1%, and less than 1% in our total gross profit percentage for the fiscal years ending June 30, 2023, 2022, and 2021, respectively. In future filings, the Company intends to include extended warranty and service revenues in our disclosures under ASC…

We respectfully advise the Staff that in future filings we will disclose in Note 2, “Revenue Recognition”, an additional disaggregation of the Company’s revenues by reportable segment using the following distribution channels: Retail, Foodservice, Export and Other. These distribution channels are consistent with our disclosures in Note 20, “Reportable Segments”. Note 21. Commitments and Contingencies Litigation, page 86

As indicated in the referenced AICPA guidance, the Fund believes there is inherent judgement regarding collectability of interest and principal that is required to appropriately apply the accounting principles for revenue recognition of non-accrual income. Judgement is required in both (a) Section 2.129 to determine the certainty of whether the cost basis can be recovered through sale or redemption and (b) Section 2.131 to determine the probability of whether interest will be collected and can reasonably estimate the amount of uncollectible interest. Furthermore, the Fund believes it is important for the readers of the financial statements to understand that management’s judgement is used in applying these accounting principles. The Fund will also clarify the language of its accounting policy to specifically reference treatment of interest received on non-accrual investments to more…

PhunToken Sales Breakdown The Company sold PhunToken for sales proceeds of approximately $1.06 million and $1.56 million during the years ended December 31, 2021 and 2022, respectively. $6,500 and $2,500, respectively, of such proceeds were derived from sales to senior management and other employees of the Company, with the remainder sold to third party customers. None of the $2.6 million was issued as a reward to consumers. Securities and Exchange Commission Division of Corporation Finance May 28, 2024 Page 3 PhunToken Issuance to Consumers Consumers can earn/accrue PhunToken rewards by participating in certain activities (e.g., answering surveys, watching videos, completing tasks, visiting points of interest, or referring consumers). It is important to note that accrued PhunToken rewards are not on-chain tokens (i.e., do not reside on the Ethereum blockchain), they are simply tracked…

The Company acknowledges the Staff’s comment and respectfully advises the Staff that it determined the allowance for credit loss balance by considering ASC 326 – Financial Instruments – Credit Losses (“ASC 326”). The Company adopted ASC 326, which requires accounts receivable to be carried at their carrying amount less an allowance for credit loss. The Company maintains an allowance for credit losses resulting from the potential inability of its customers to make required payments based on contractual terms. The Company reviews the collectability of its receivables on a regular and ongoing basis. In accordance with ASC 326-20-30-2 and 55-5, in order to assess collectability, the Company reviews accounts receivable on a collective basis for customers that share similar risk characteristics and on an individual basis for those customers that do not share similar risk characteristics. In…

The Company acknowledges the Staff’s comment and respectfully advises the Staff that the Company’s arrangements that contain variable consideration include transportation services arrangements with billings to third party payors and healthcare facilities. The estimate of variable consideration is typically not constrained as set forth in ASC 606-10-50-12(b). Although it does not impact any previously disclosed results, in light of the Staff's comment, the Company will provide the following revised disclosure that will include additional quantitative and qualitative information as required by ASC 606-10-50-1(b) in future periodic filings beginning with the Company's Quarterly Report on Form 10-Q for the quarterly period ending June 30, 2024. For the Staff's reference, set forth below is an illustrative example of how such revised disclosure would have appeared in the Company’s Annual…

The Company acknowledges the Staff’s comment and respectfully advises the Staff that the Company disaggregates revenue into the United States and United Kingdom geographic markets as well as into the Mobile Health Services and Transportation Services major operating segments lines, as this best reflects how the Company views and manages its business. Regarding the disaggregation of revenue into the United States and United Kingdom, the Company provides this entity-wide disclosure about the geographic areas in which the Company generates its revenues in accordance with ASC 280-10-50-41. The Company generates revenues from two types of services: Mobile Health Services, which include a wide variety of healthcare services performed at homes, offices and other locations and event services such as on-site healthcare support at sporting events and concerts; and Transportation Services, which…

In response to the Staff’s comment, the Company has amended its disclosure on page F-9 of the Registration Statement. We thank the Staff very much for its review of the foregoing. If you have questions or further comments, please feel free to contact our counsel, Wei Wang, Esq., at Ellenoff Grossman & Schole LLP by telephone at (212) 370-1300. Sincerely, /s/ Yushun Ting Yushun Ting, President and Chief Executive Officer cc: Wei Wang Ellenoff Grossman & Schole LLP

We respectfully acknowledge the Staff’s comment, but we have determined that the Company’s current aggregate revenue presentation is appropriate based on the guidance set forth in Rule 5-03(b) of Regulation S-X. Service revenue comprised less than 10% of the Company’s revenues in the fiscal years ended October 31, 2023, 2022, and 2021. As such, in accordance with Rule 5-03(b), service revenue and any related cost of sales have not been presented separately on the Company’s statements of operations. To the extent the percentage of our service revenue exceeds 10% of total revenue, we will modify the presentation.

We respectfully acknowledge the Staff’s comment and, based on the ASC 606 disclosure requirements, we believe that the Company’s disclosure of its revenue recognition policy is appropriate. As part of satisfying ASC 805 Business Combinations disclosure requirements, we disclosed that Generate Life Sciences (“Generate”) revenues for the period from the acquisition date to October 31, 2022, were $249.5 million, which accounted for 8% of the Company’s total consolidated revenue in fiscal year 2022. Also, as disclosed in our response to Comment #2 above, service revenue accounted for less than 10% of our total consolidated revenue in fiscal year 2023. Taking into account the magnitude of revenue and the deferred revenue balance, we previously included disclosures related to the majority of the deferred revenue balance in the 10-K for the fiscal year ended October 31, 2023 which explained…

We have considered the guidance in ASC 606-10-50-5 and 50-6 with respect to disaggregated revenue disclosures in our filings. Under this guidance, we note that disaggregated revenue disclosures are required if the nature, amount, timing, and uncertainty of revenue and cash flows are impacted by different economic factors. Further, we note that ASC 606-10-55-89 provides that the extent to which the disaggregated revenue information is provided depends on facts and circumstances pertaining to the underlying contracts with customers. Finally, we considered the examples discussed in ASC 606-10-55-91, acknowledging this is a non-exclusive list. As disclosed in our Form 10-K financial statements Note 3, our revenue is derived from the manufacture and sale of fiber-based packaging and pulp goods. With respect to our Industrial Packaging segment, we generate revenue through the sale of various…

We have noted your comment and in future filings will revise our disclosure to clarify when control of our Precast products transfers. The following is our proposed disclosure (with additions marked as underlined): “Precast revenue for water infrastructure concrete pipe and precast concrete products is recognized at the time control is transferred to customers which is generally at the time of shipment , in an amount that reflects the consideration we expect to be entitled to in exchange for the products. All variable consideration that may affect the total transaction price, including contractual discounts, returns, and credits, is included in net sales. Estimates for variable consideration are based on historical experience, anticipated performance, and management’s judgment. Our contracts do not contain significant financing.” Pursuant to your comment, we acknowledge that a) we are…

In response to the Staff’s comment, the Company revised disclosure on page F-34 of the Amended Registration Statement to add the following: “The customers of the remittance services are financial institutions (referred to as “Remittance Partners”). Remittance Partners who use the fiat currency prefunding option for their remittance business with the Company are referred to as Fiat Currency Prefunded Remittance Partners, whereas customers who choose the XRP Prefunding mode are referred to as XRP Prefunded Remittance Partners.” (gg) Prefunding to remittances partner, page F-39

In response to the Staff’s comment, the Company has revised its disclosure on page F-59 of Amendment No. 3. Cycurion enters into service agreements with customers that set forth the responsibilities of Cycurion and its customers, including the type of service to de delivered, the timing of the delivery of those services, and the associated price per unit for such services. The unit of measure in the agreement is typically hours. The service agreements also set forth the timing of payments by the customers, which is typically between 60 and 90 days from the date that an invoice is issued to the customer. Cycurion issues invoices when management has received an acknowledgement from the customer that Cycurion has rendered the services as measured in hours to the customer. As a practical matter, Cycurion continuously delivers services to customers, and the customers receive benefits from…

In response to the Staff’s comment, Cycurion has revised its disclosure on page 146 of Amendment No. 3 and has removed that language in Amendment No. 3.

In response to the Staff’s comment, Cycurion has revised its disclosure on page 146 of Amendment No. 3 and has removed that language in Amendment No. 3. Note 4 - Refundable Deposit for Acquisition, page F-54

The Company acknowledges the Staff’s comment. Our integrated kidney care (“IKC”) revenue is substantially composed of revenue from three primary sources: (i) special needs plans, (ii) our value-based care (“VBC”) contracts with health plans focused primarily on Medicare Advantage (“MA”) patients, and (iii) the CMS Comprehensive Kidney Care Contracting (“CKCC”) demonstration program for our Medicare fee-for-service patients. The following discussion pertains only to the VBC contract portion of our IKC business. Our revenue recognition policy and accounting for these IKC arrangements are described in Notes 1 and 2 to the consolidated financial statements included in our 2023 10-K. Introductory summary The $55 million IKC adjustment referred to in the “Company overview” and “Ancillary services results of operations” sections of the 2023 10-K’s Management Discussion and Analysis (MD&A)…

Part A of Comment #2 The Company acknowledges the Staff’s comment. To address the first sentence of the Staff’s comment 2, the Company will revise its disclosures in future filings to describe the composition of non-GAAP adjustments and include expanded discussion of the rationale for the Company’s determination that non-GAAP adjustments are not indicative of ordinary results of operations. The proposed additional disclosure for future filings is set forth below: Non-GAAP adjustments may include, but are not limited to, certain items such as center closure costs (net losses on retired assets, lease costs, asset impairments and accelerated depreciation and amortization), goodwill impairments, severance and other restructuring costs, significant legal settlement accruals, debt extinguishment and modification costs, and significant adjustments to recognized shared savings earnings in our…

The 10-K/A reflects the removal of this disclosure. 2 Revenue Recognition, page 34

The customer in our bitcoin mining transactions is our mining pool operator. Our Revenue Recognition disclosure has been revised in the 10-K/A and states, “[t]o generate revenue from mining bitcoin, the Company has entered into digital asset mining pools by executing contracts, as amended from time to time, with the mining pool operators to provide computing power to the mining pool.” · Confirm if mining pool in which you participate utilizes the Full Pay Per Share (FPPS) payout method;

In response to the Staff’s comment, NEH has revised Note 15 in its financial statements to indicate that the transportation and processing costs are a reduction of only the natural gas revenues. Oil and Natural Gas Reserves, page F-86

The Company acknowledges that from a quantitative perspective, revenues associated with managed business travel (as the Company defines them) are material to overall Passenger and Operating Revenues within the Income Statement. However, in its initial response, the Company was attempting to convey that in fulfilling its obligation to explain trends and year-over-year variances within Management's Discussion and Analysis in the periods presented in the financial statements that were the source of the Staff’s question, changes in managed business travel revenues are a relatively small component of the year-over-year variances within these line items, and they were not the primary or even secondary driver of these variances, and thus were not considered a required disclosure item in those filings. If year-over-year changes in business travel revenues were to represent a significant driver…

Disaggregated revenue disclosures pursuant to ASC 606-10-50-5 and SEC 606-10-55-89 through 55-91: We referred to the guidance in ASC 606-10-50-5 to assess how the nature, amount, timing, and uncertainty of revenue and cash flows are affected by various economic factors in order to disaggregate revenue into useful categories. When determining the most appropriate categories by which to disaggregate revenue for disclosure, we considered the following implementation guidance described in ASC 606-10-55-91: (a) Type of good or service – We design, develop, manufacture, ship and support control and sensor technology solutions and a broad line of universal control systems, audio-video accessories, wireless security and smart home products. Each product follows the same development, production, and sales cycle, which consists of internal design and engineering, quality management and testing,…

The Registrant has included the disclosures required by ASC 606-10-32- 2A in the Revised Registration Statement on page F-10. General

The following documentation represents a comprehensive accounting analysis of the Hosting Contracts under ASC 606, Revenue from Contracts with Customers . ASC 606 requires entities to assess their contracts to determine the timing and amount of revenue to recognize under the revenue standard. Per ASC 606-10-05-3, the core principle of the revenue standard “ is that an entity recognizes revenue to depict the transfer of promised goods or services to customers in an amount that reflects the consideration to which the entity expects to be entitled in exchange for those goods or services. ” The core principle is the underpinning of the entire revenue framework and should be followed by applying the following five steps. “ 606-10-05-04 An entity recognizes revenue in accordance with that core principle by applying the following steps: a. Step 1 : Identify the contract(s) with a customer —A…

Please refer to our comprehensive accounting analysis above that addresses each of the five steps outlined in ASC 606-10-05-4, including this specific comment on page 9 above. • With regards to step one in ASC 606-10-05-4: o Expand your analysis to more fully address ASC 606-10-25-1 through 25-9.

We respectfully advise the Staff that the revenue recognition policies disclosed for vehicle sales without Residual Value Guarantee apply to vehicles sales under the EV Purchase Agreement. In future filing, beginning with our Quarterly Report on Form 10-Q for the quarter ended March 31, 2024, we will disclose that the revenue recognition policies for vehicle sales without Residual Value Guarantee apply to vehicles sales under the EV Purchase Agreement. Note 20 - Related Party Transactions, page 129

We are informed the Company has revised this disclosure to state that software that the customer takes possession of is recognized as when the software is delivered . Item 8. Exhibits and Financial Statement Schedules, page 150

The Company acknowledges the Staff's comment. The Company confirms that contracts are terminable at any time without penalty, the contract term is shorter than a 24-hour period, and is continuously renewed. The Company will revise our disclosure in our future filings to clarify this and remove any references to daily contracts or midnight contract inception. • Tell us your consideration of disclosing that the services you provide are an output of your ordinary activities.

In response to the Staff’s comment, please see the revised disclosure on page F-11 of the FYE 2023 Financials, under “Pay-it-forward Revenue,” which includes more detailed disclosure to address (i) the amount of Pay-it-forward revenue deferred for each period presented for future movie ticket purchases, (ii) other types of material revenue being deferred, and (iii) when the Company expects to recognize such related revenue. Content Licensing, page F-27

In response to the Staff’s comment, please see the revised disclosure on pages F-11 and F-12 of the FYE 2023 Financials, which includes more detailed disclosure to address the typical duration of the Company’s content licensing arrangements, and the amount of time from when the Company records the estimated royalty revenue to when such revenue is trued up and the amount of adjustment is recorded. Pay-It-Forward Revenue, page F-27

TO COMMENT 3 In response to the Staff's comment, we will enhance our future revenue recognition disclosures related to telecom products and services to (i) more fully explain the nature and type of our telecom products and services, (ii) define "airtime" and explain related sales and inventory processes, and (iii) more fully explain how revenue is measured and recognized for this business. I am available to discuss our response at your convenience. Please do not hesitate to call me at +27 11 343 2000, if you have any questions or comments regarding the foregoing or need any additional information. Thank you. Very truly yours, Lesaka Technologies, Inc. By: /s/ Naeem E. Kola Name: Naeem E. Kola Title: Group Chief Financial Officer

The Company acknowledges the Staff’s comment and advises the Staff that customer cost recoveries represent reimbursements the Company receives from customers for incremental costs associated with spot purchases of raw materials and premium freight incurred in fulfilling its performance obligation to the customer. Given these cost recoveries are generally negotiated after contract inception, the Company accounts for these cost recoveries as a modification to the existing contract. The Company recognizes cost recoveries as revenue when (or as) the remaining performance obligations per the contract are satisfied, or on the modification date if all performance obligations under the contract have been previously satisfied. In future filings, the Company will include additional disclosure in its revenue recognition policy regarding customer cost recoveries. Critical Accounting Policies and…

The Company acknowledges the Staff’s comment related to the Company’s indemnification disclosure on F-39. On page 9 of the Form 10-K, under “ Product Rights and Indemnification ”, the Company discloses (emphasis added): “… Under our various license agreements, we expressly represent and warrant that unaltered content downloaded and used in compliance with our license agreements and applicable law will not infringe any copyright, trademark or other intellectual property right, violate any third-party’s rights of privacy or publicity, violate any U.S. law, be defamatory or libelous, or be pornographic or obscene. Provided that a customer has not breached the license agreement or any other agreement with us, we will defend, indemnify, and hold a customer harmless from direct damages attributable to breaches of the express representations and warranties provided in our license agreements .…

The Company acknowledges the Staff’s comment. Pursuant to the United Kingdom Competition and Markets Authority’s (the “CMA”) final order requiring Meta to divest its ownership of Giphy, [***]. [***]. [***]. [***]. Separately, in connection with the closing of the acquisition, the Company and Meta entered into a Transition Services Agreement (the “TSA”). [***]. Accordingly, upon acquisition, this $30 million of consideration, as set forth in the TSA and allocated to the API arrangement, was recorded as an account receivable with an accompanying $30 million in deferred revenue. For the year ended December 31, 2023, approximately $10.0 million was recognized as revenue (representing revenue from the acquisition date to December 31, 2023), of which $7.5 million related to the $30 million of deferred revenue described above . In future filings, the Company will amend its disclosure relating…

We acknowledge the Staff’s comments and will revise the revenue recognition paragraph under Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Critical Accounting Estimates and Policies in future filings, beginning with our Form 10-K for the year ended September 30, 2024, to ensure that the disclosures properly address the guidance under ASC 606. Notes to Consolidated Financial Statements 1. Organization and Summary of Significant Accounting Policies Customers, page 64

In future filings we will revise the header from “Critical Accounting Policies” to “Critical Accounting Estimates,” and in the annual reports we will include a subheading for property and equipment. In the quarterly reports, we simply cross-reference the applicable disclosure in the notes to the financial statements and expect to continue that process going forward. Regarding disclosure of the $122,950 impairment loss, we intend to include enhanced narrative disclosure of material transactions relating to property and equipment in the financial statement note concerning same, beginning with the Current Form 10-Q. Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters, page 78

The answers to each sub-question of this comment are: · While the mining pool contract may be terminated at any time during a day, that would not change the fact that the mining pool operator would still only calculate the Company’s share of rewards over the course of the entire day. Its rewards would not be determined at termination, but at midnight UTC on the date of termination, and paid in its normal course several hours later by a transfer to the Company’s wallet account based on the computing power contributed by the Company over the entire 24 hour day, even though the Company may have disconnected its machines from the mining pool mid-day when it elected to terminate the agreement. Furthermore, treating the contract as being a series of one second agreements throughout the day, with separate pricing for each one second contract based on the price of bitcoin for that split second,…

The Company acknowledges the Staff’s comment and notes that, in accordance with ASC 606-10-55-36, the Company recognizes extended warranty revenue on a gross basis over time (rather than 6 on a net basis at the time the contracts are sold), as the nature of its promise is a performance obligation to provide extended warranty and claims services to the end customer over the service period. When a customer purchases extended warranty or service coverage (“service contracts”) on the Company’s website, it accepts the terms and conditions of the service contract between the customer, a service contract obligor, and the Company as the administrator and seller. Under these arrangements, the Company is considered the primary obligor. The Company sets the price and collects payment from the customer on the sale of the service contract and remits a fee to the service contract obligor on that…

Please see the discussion above and note the Company’s revised definition of ARR is as follows (bold text represents new language, strikethrough represents deleted language): Annual ized Recurring Revenue (“ARR”) We are providing an disclose ARR as a performance metric to help investors better understand and assess the performance of our business because our mix of revenue generated from recurring sources currently represents the substantial majority of our revenues and is expected to continue in the future has increased in recent years . We define ARR as the annualized recurring revenue of term-based contracts from all customers at a point in time. ARR represents the annualized contract value for all active and contractually binding term-based contracts at the end of a period. ARR includes revenue from maintenance, software upgrade rights, public cloud, and on-premises…

With respect to the first bullet point above, our valuation business revenue is included in our consulting revenue and our game website revenue is reported separately. Specifically, our game website revenue amounted to $1,192 in fiscal 2023 and $1,155 in fiscal 2022. It is not a material component of our operations, and we described it as other revenue when breaking out the components of revenue on page 32 of Form 10-K. It was not significant enough to disclose on page 6 of Form 10-K, where we discussed the components of our business. We mentioned the game website because it is a subscription-based business that requires users to pay in advance. Consequently, on each balance sheet, there has been deferred revenue from the game website, which amounted to $661 as on April 30, 2023. We consider the valuation business a consulting activity and we include its revenues with consulting…

The description of our revenue on page 51 should have been more descriptive as in actuality the revenue was a short-term agreement with another pharmaceutical company to utilize some of our laboratory space, equipment, and assistance from some of our personnel on development and testing of their product. The effort took longer than originally anticipated, however, shortly after our year end (August 31, 2023), the project was completed, and we do not expect to see any further revenue until our product launches. There was no revenue generated from license agreements, or other “sales” related activity. This was a one-off opportunity to help another company and cover some of our overhead costs as well. If such an opportunity develops in the future, we will provide a more detailed description of the revenue generated as per ASC 606. Going forward, we, as management will provide as much…

In light of Staff comments, in addition to the disclosure that the estimate changes were immaterial to the periods presented, we have determined we will enhance our disclosures in future filings, beginning with our Annual Report on Form 10-K for the fiscal year ending April 27, 2024, to further comply with the requirements of ASC 606-10-50-17 relating to the disclosure of judgments and changes in estimates made in the application of ASC 606. In future filings, beginning with the Annual Report on Form 10-K for fiscal 2024, we will include a discussion in “Note 1. Nature of Business and Summary of Significant Accounting Policies” in the section entitled “Revenue recognition” to further describe the significant judgments used in the estimation process and add clarity to our accounting policy over estimate changes. The following is an example of the enhanced disclosure: Estimated contract…

The Company acknowledges the Staff’s comment. In all future periodic filings, commencing with our Form 10-Q for the quarter ending March 31, 2024, we will revise our disclosures to include a quantitative breakdown using smaller time bands, including how much the Company expects to recognize in the next 12 months for connectivity and entertainment service remaining performance obligations. For equipment revenue remaining performance obligations, which have an inherently shorter time band of three years, the Company will include additional qualitative information in these disclosures. The Company is unable to quantify the remaining performance obligations for equipment revenue using smaller time bands with reasonable accuracy as the timing of equipment revenue recognition is driven by the timing of customer orders which are inherently uncertain and out of the Company’s control. The…

Bullet 1 - Nature of Services Provided by ALT to Sera Labs Revised disclosure in the Revenue Recognition section on page F-18 is as follows: ALT was engaged by the Company to provide a range of auxiliary services to Sera Labs designed to support the direct-to-consumer (DTC) sales channel, enhancing the efficiency and effectiveness of our product distribution. These services include, but are not limited to, processing customer payments, handling customer service inquiries, and managing logistics and fulfillment coordination with RT Fulfillment (RTF). ALT's role is instrumental in facilitating the seamless operation of our DTC model, acting as an extension of our operational infrastructure to ensure customer satisfaction and streamline sales processes. However, ALT does not have its own employees and the management of the aforementioned processes is performed by employees of Sera Labs.…

The Company respectfully acknowledges the Staff’s comment and respectfully advises the Staff that it will update its disclosure in its future filings to address the matter. We will update our disclosure to provide clarifying detail in accordance with ASC 606-10-50-12(a) as follows: The Company recognizes revenue as performance obligations are fulfilled when control passes to customers, which is typically upon delivery of the products to its customers. Consolidated Financial Statements 2. Summary of Significant Accounting Policies and Practices Revenue Recognition, page 52 Staff

As noted above, during the first quarter of fiscal year 2024, the Company initiated the Hain Reimagined Program, an initiative prompted by our then-new Chief Executive Officer. The primary objectives of this program are to optimize our portfolio, enhance underlying profitability, and bolster our agility in pursuing targeted growth initiatives. Additionally, the program aims to fortify brand building and other critical capabilities essential for sustained future growth. Historically, the Company operated within three broad product categories—namely, Growth, Fuel, and Simplify—and a strategic evaluation of this portfolio was a key component of the Hain Reimagined Program. In September 2023, the Company announced the Hain Reimagined Program which highlighted reorganization of the Company’s portfolio around five consumer-centric global platforms: snacks, baby/kids, beverages, meal…

The Company respectfully acknowledges the Staff’s comment and has revised its disclosure accordingly on pages 1, 47 and 61 of Amendment No. 1, as the Company does not feel the disaggregation of revenue based on the types of customers and/or geographic region to be useful information for investors. In the Company’s view, (i) this information is not material information that the Company uses to make operational decisions and (ii) the market for freeze dried candy is in such a nascent stage and the demand for the Company’s treats is too far beyond the Company’s manufacturing capacity, such that the types of customer to whom the Company sells and the geographic regions in which their products are sold have not solidified in a way where the Company believes the disaggregation of revenue would provide investors with information indicative of the Company’s direction. Principal Stockholders,…