January 29, 2021
Via EDGAR
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention: Tony Watson
Adam Phippen
Re: º¬Ð߲ݴ«Ã½.
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed February 26, 2020
File No. 001-33982
Dear Mr. Watson and Mr. Phippen,
Set forth below is a response to the comment contained in the Staff’s letter to Brian J. Wendling, Chief Accounting Officer and Principal Financial Officer of º¬Ð߲ݴ«Ã½. (“QRI”), dated January 27, 2021, regarding the QRI Form 10-K for the fiscal year ended December 31, 2019 (the “Form 10-K”). For your convenience, our response below is preceded by the Staff’s comment.
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Form 10-K for the Fiscal Year Ended December 31, 2019
Consolidated Statements of Operations, page II-32
| 1. | Comment: We read your response to comment one. In future filings, if you exceed the new thresholds in Rule 1-02(w) of Regulation S-X then you should provide the information in Rule 4-08(g) of Regulation S-X or contact the Division of Corporation Finance Office of the Chief Accountant to discuss the possibility of a potential waiver. |
Response: We will continue to monitor the significance of our investments accounted for using the equity method under the new thresholds in Rule 1-02(w) of Regulation S-X. Should we exceed the new thresholds, we will either contact the Division of Corporation Finance Office of the Chief Accountant to inquire about the possibility of a potential waiver or include the applicable disclosures.