SEC Comment Letter for AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504) (UAVS) — Sep 8, 2016
AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504)
Date: Sept. 8, 2016 · CIK: 0000008504 · Accession: 0000000000-16-091948
AI Filing Summary & Sentiment
Letter
Mail Stop 4628 September 8, 2016 Via E -Mail Robert G. Watson Jr. Chief Executive Officer EnerJ ex Resources, Inc. 4040 Broadway, Suite 508 San Antonio, TX 78209
Re: Ener Jex 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 comments , we may have additional comments. Unless we note otherwise, our references to prior comments are to comment s in our July 11 , 2016 letter.
Form 10 -K for the Fiscal Year ended December 31, 2014
Notes to Consolidated Financial Statements
Supplemental 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, including your illustration of the proposed disclosure regarding the beginning and end -of-year quantities for each product type of proved developed and proved undeveloped reserves. Please revise your proposed
Robert G. Watson, Jr. Ener Jex Resources, Inc. September 8, 2016 Page 2
discl osure to correct the mathematical inconsistencies in the calculation of the figures in the illustration. Also revise your proposed disclosure to resolve the inconsistencies regarding the beginning and end -of-year quantities in your illustration compared t o the quantities provided in Form 10 -K for the fiscal years ending December 31, 2014 and 2013, respectively.
2. Please expand your disclosure to provide a narrative explanation for the significant changes in net reserves relating to each line item entry othe r than production for each of the periods presented. Refer to the disclosure requirements in FASB ASC 932 -235-50-5.
Form 10 -K for the Fiscal Year ended December 31, 2015
Notes to Consolidated Financial Statements
Supplemental Oil and Gas Reserve Infor mation (Unaudited), page F -17
Estimated Quantities of Proved Reserves, page F -18
3. To the extent applicable, please incorporate the disclosure revisions identified in your response to comment one regarding the presentation of total net proved reserves, developed reserves and undeveloped reserves along with the changes in net quantities for the periods ending December 31, 2014 and 2015, respectively, as disclosed in the Form 10-K for the fiscal year ending December 31, 2015.
You may contact John Hodgin, Pet roleum 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 September 8, 2016 Via E -Mail Robert G. Watson Jr. Chief Executive Officer EnerJ ex Resources, Inc. 4040 Broadway, Suite 508 San Antonio, TX 78209 Re: Ener Jex 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 comments , we may have additional comments. Unless we note otherwise, our references to prior comments are to comment s in our July 11 , 2016 letter. Form 10 -K for the Fiscal Year ended December 31, 2014 Notes to Consolidated Financial Statements Supplemental 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, including your illustration of the proposed disclosure regarding the beginning and end -of-year quantities for each product type of proved developed and proved undeveloped reserves. Please revise your proposed Robert G. Watson, Jr. Ener Jex Resources, Inc. September 8, 2016 Page 2 discl osure to correct the mathematical inconsistencies in the calculation of the figures in the illustration. Also revise your proposed disclosure to resolve the inconsistencies regarding the beginning and end -of-year quantities in your illustration compared t o the quantities provided in Form 10 -K for the fiscal years ending December 31, 2014 and 2013, respectively. 2. Please expand your disclosure to provide a narrative explanation for the significant changes in net reserves relating to each line item entry othe r than production for each of the periods presented. Refer to the disclosure requirements in FASB ASC 932 -235-50-5. Form 10 -K for the Fiscal Year ended December 31, 2015 Notes to Consolidated Financial Statements Supplemental Oil and Gas Reserve Infor mation (Unaudited), page F -17 Estimated Quantities of Proved Reserves, page F -18 3. To the extent applicable, please incorporate the disclosure revisions identified in your response to comment one regarding the presentation of total net proved reserves, developed reserves and undeveloped reserves along with the changes in net quantities for the periods ending December 31, 2014 and 2015, respectively, as disclosed in the Form 10-K for the fiscal year ending December 31, 2015. You may contact John Hodgin, Pet roleum 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