Greenidge Generation Holdings Inc

The Company received comments from the SEC’s Division of Corporation Finance Office of Crypto Assets (the “Staff”) during fiscal year 2023 requiring certain revisions to be made to the Company’s accounting policies and which remain unresolved:

•Revenue recognition. The Staff commented on the Company’s revenue recognition policy in its capacity as a pool participant, including with respect to requesting additional information regarding its participation in mining pools, the payout methodology utilized by such pools, and the contract terms with such operators. The Staff further commented on the Company’s accounting convention to recognize noncash (Bitcoin) revenue using fair value on the day of receipt versus contract inception. In response to the Staff’s comments, the Company has revised Note 2 – Summary of Significant Accounting Policies in the notes to our consolidated financial statements to, among other things, include additional disclosure regarding its mining pool participation, its contract terms with such pool operators, its performance obligation under such contracts, and the mining pool payout methodology, including FPPS, and the valuation of noncash consideration. The Company also evaluated, and provided its analysis for, the difference between its current accounting convention regarding the recognition of noncash (Bitcoin) revenue and fair value at contract inception and determined that any differences in revenue were not material for the stated periods.

•Principal market. The Staff commented on the Company’s prior designation of a recognized cryptocurrency price-tracking website as its principal market for its digital assets as opposed to the market where the Company would normally sell its digital assets. In response to the Staff’s comments, the Company has revised Note 2 – Summary of Significant Accounting Policies in the notes to our consolidated financial statements to clarify that the Company’s principal market is Coinbase. The Company also evaluated, and provided its analysis for, the difference between the fair value of, and any potential impairment in, its digital asset holdings utilizing Coinbase as opposed to its formerly designated principal market, and determined that any differences were not material for the stated periods.