TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo May 13, 2022 David Watson Chief Financial Officer Argan, Inc. One Church Street, Suite 201 Rockville, MD 20850 Re: Argan, Inc. Form 10-K for the fiscal year ended January 31, 2022 Form 8-K Filed April 13, 2022 File Nos. 001-31756 Dear Mr. Watson: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. 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 comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 8-K filed April 13, 2022 Exhibit 99.1 Summary Information, page 1 1. We note your presentation of EBITDA per diluted share for the fiscal years ended January 31, 2022 and 2021. Please tell us how your presentation complies with the guidance in Questions 103.02 and 102.05 of the Compliance and Disclosure Interpretations for Non- GAAP Financial Measures. In closing, we remind you that the company and its management are responsible for the David Watson Argan, Inc. May 13, 2022 Page 2 accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Jeffrey Lewis, Staff Accountant, at (202) 551-6216 or Isaac Esquivel, Staff Accountant, at (202) 551-3395 with any questions. FirstName LastNameDavid Watson Sincerely, Comapany NameArgan, Inc. Division of Corporation Finance May 13, 2022 Page 2 Office of Real Estate & Construction FirstName LastName