Richard A. Krantz | Partner
200 Park Avenue
Suite 1700
New York, New York 10166
Office: 646-632-3730
Cell: 203-362-8007
rkrantz@cm.law
May 16, 2022
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Jeffrey Lewis, Staff Accountant
Isaac Esquivel, Staff Accountant
Re: Argan, Inc.
Form 8-K
Filed April 13, 2022
File No. 001-31756
Ladies and Gentlemen:
This firm represents Argan, Inc., a Delaware corporation (“Argan”), which received your comment letter dated May 13, 2022 (the “Comment Letter”).
Set forth below is Argan’s response to the Comment Letter regarding its Form 8-K filed on April 13, 2022. Argan affirms that it is responsible for the accuracy and adequacy of the disclosures that have been made in its filings, notwithstanding any review, comments, action, or absence of action by the staff. Argan’s response to the Comment Letter is as follows:
Form 8-K Filed April 13, 2022
Exhibit 99.1
Summary Information, page 1
Comment
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.
Response
Argan hereby confirms that it will omit any non-GAAP per share information in future press releases that include financial results and in future filings with the Commission.
Page | 2
It should be noted that non-GAAP per share information has never been included in Argan’s Annual Reports on Form 10-K or its Quarterly Reports on Form 10-Q.
If you have any additional concerns or comments, please contact the undersigned.
Sincerely,
/s/ Richard A. Krantz
CULHANE MEADOWS PLLC
www.culhanemeadows.com