SEC Comment Letter for AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504) (UAVS) — May 11, 2016
AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504)
Date: May 11, 2016 · CIK: 0000008504 · Accession: 0000000000-16-075955
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4628 May 11, 2016 Via E -Mail Robert G. Watson Jr. Chief Executive Officer Enerjex Resources, Inc. 4040 Broadway, Suite 508 San Antonio, TX 78209
Re: Enerjex Resources, Inc. Form 10-K for the Fiscal Year ended December 31, 2014 Filed March 31, 2015 Form 10 -K for the Fiscal Year ended December 31, 2015 Filed April 11, 2016 File No. 1 -36492
Dear Mr. Watson :
We have reviewed your filings and response letter and have the following comment s. In some of our comments , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comm ents, we may have additional comments. Unless we note otherwise, our references to prior comments are to comment s in our March 4, 2016 letter.
Form 10 -K for the Fiscal Year ended December 31, 2014
Notes to Consolidated Financial Statements
Supple mental Oil and Gas Reserve Information (Unaudited), page F -18
Estimated Quantities of Proved Reserves, page F -19
1. We have read your response to prior comment one and see that although your proposed disclosure revisions address the requirements regarding the separate disclosure by product type of changes in your proved developed and undeveloped reserves combined,
Robert G. Watson, Jr. Enerjex Resources, Inc. May 11, 2016 Page 2
for the periods ending December 31, 2014 and 2013, these do not specify the beginning and end -of-year quantities for each product type of proved developed reserves apart from proved undeveloped reserves, which is also required. Please further revise your discl osure to provide these details. You may refer to FASB ASC 932 -235-55-2 for illustrations of the presentation requirement of FASB ASC 932 -235-50-4. To the extent applicable, please incorporate these revisions in the Form 10 -K for the fiscal year ending December 31, 2015 as well.
Form 10 -K for the Fiscal Year ended December 31, 2015
Notes to Consolidated Financial Statements
Supplemental Oil and Gas Reserve Information (Unaudited), page F -17
Estimated Quantities of Proved Reserves, page F -18
2. We note di sclosure indicating you have not converted material quantities of proved undeveloped reserves to developed reserves for the years ending December 31, 2015 and 2014. Please provide us with your development schedule, indicating for each future period, the n et quantities of proved reserves and estimated capital expenditures necessary to convert all of the proved undeveloped reserves disclosed as of December 31, 2015 to developed. Please refer to Rule 4 -10(a)(31)(ii) of Regulation S -X and Question 131.04 in the Compliance and Disclosure Interpretations (C&DIs), issued October 26, 2009 and updated May 16, 2013, and either confirm or tell us the extent to which all of the proved undeveloped locations are part of a development plan that has been adopted by your management, including approval by your Board of Directors, if such approval is required, and is current as of December 31, 2015.
You may contact John Hodgin, Petroleum Engineer, at (202) 551 -3699 if you have questions regarding the comments. Please contact Karl Hiller, Branch Chief, at (202) 551 -3686 with any other questions.
Sincerely,
/s/H. Roger Schwall
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Mail Stop 4628 May 11, 2016 Via E -Mail Robert G. Watson Jr. Chief Executive Officer Enerjex Resources, Inc. 4040 Broadway, Suite 508 San Antonio, TX 78209 Re: Enerjex Resources, Inc. Form 10-K for the Fiscal Year ended December 31, 2014 Filed March 31, 2015 Form 10 -K for the Fiscal Year ended December 31, 2015 Filed April 11, 2016 File No. 1 -36492 Dear Mr. Watson : We have reviewed your filings and response letter and have the following comment s. In some of our comments , we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comm ents, we may have additional comments. Unless we note otherwise, our references to prior comments are to comment s in our March 4, 2016 letter. Form 10 -K for the Fiscal Year ended December 31, 2014 Notes to Consolidated Financial Statements Supple mental Oil and Gas Reserve Information (Unaudited), page F -18 Estimated Quantities of Proved Reserves, page F -19 1. We have read your response to prior comment one and see that although your proposed disclosure revisions address the requirements regarding the separate disclosure by product type of changes in your proved developed and undeveloped reserves combined, Robert G. Watson, Jr. Enerjex Resources, Inc. May 11, 2016 Page 2 for the periods ending December 31, 2014 and 2013, these do not specify the beginning and end -of-year quantities for each product type of proved developed reserves apart from proved undeveloped reserves, which is also required. Please further revise your discl osure to provide these details. You may refer to FASB ASC 932 -235-55-2 for illustrations of the presentation requirement of FASB ASC 932 -235-50-4. To the extent applicable, please incorporate these revisions in the Form 10 -K for the fiscal year ending December 31, 2015 as well. Form 10 -K for the Fiscal Year ended December 31, 2015 Notes to Consolidated Financial Statements Supplemental Oil and Gas Reserve Information (Unaudited), page F -17 Estimated Quantities of Proved Reserves, page F -18 2. We note di sclosure indicating you have not converted material quantities of proved undeveloped reserves to developed reserves for the years ending December 31, 2015 and 2014. Please provide us with your development schedule, indicating for each future period, the n et quantities of proved reserves and estimated capital expenditures necessary to convert all of the proved undeveloped reserves disclosed as of December 31, 2015 to developed. Please refer to Rule 4 -10(a)(31)(ii) of Regulation S -X and Question 131.04 in the Compliance and Disclosure Interpretations (C&DIs), issued October 26, 2009 and updated May 16, 2013, and either confirm or tell us the extent to which all of the proved undeveloped locations are part of a development plan that has been adopted by your management, including approval by your Board of Directors, if such approval is required, and is current as of December 31, 2015. You may contact John Hodgin, Petroleum Engineer, at (202) 551 -3699 if you have questions regarding the comments. Please contact Karl Hiller, Branch Chief, at (202) 551 -3686 with any other questions. Sincerely, /s/H. Roger Schwall H. Roger Schwall Assistant Director Office of Natural Resources