SEC Comment Letter for MCMORAN EXPLORATION — May 11, 2005
MCMORAN EXPLORATION CO /DE/ (CIK 0000064279)
Date: May 11, 2005 · CIK: 0000064279 · Accession: 0000000000-05-023289
AI Filing Summary & Sentiment
File numbers found in text: 333-121779
Referenced dates: May 5, 2005, May 5, 2005
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<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
May 11, 2005
via U.S. Mail
Kathleen L. Quirk
Senior Vice President and Treasurer
McMoRan Exploration Co.
1615 Poydras Street
New Orleans, Louisiana 70112
Re: McMoRan Exploration Co.
Form S-3 filed April 19, 2005
File No. 333-121779
Form 10-K for the fiscal year ended December 31, 2004
Filed March 15, 2005
Response Letter dated May 5, 2005
Dear Ms. Quirk:
We have reviewed the above response letter and have the
following comment. We have limited our review to the area
commented
on below. Where indicated, we think you should revise your
documents
in response to this comment. If you disagree, we will consider
your
explanation as to why our comment is inapplicable or revision is
unnecessary. Please be as detailed as necessary in your
explanation.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Engineering Comments
10-K as of December 31, 2004
filed on March 15, 2005
Supplementary Oil and Gas Information
Standardized Measure of Discounted Future Net Cash Flows
1. In regards to your response number 1 of your letter dated May
5,
2005, please indicate specifically what portion of your oil and
gas
producing activities suffered the tax losses. Specifically name
the
properties and the reason these properties incurred the tax
losses.
We note that several years ago you were engaged in activities for
the
recovery and processing of sulfur. Please name the properties
that
these operations were conducted on and confirm that the tax loss
carryovers are unrelated to these operations.
Closing Comments
As appropriate, please respond to this letter within 10
business
days or tell us when you will provide us with a response.
Detailed
cover letters greatly facilitate our review. Please file your
cover
letter on EDGAR. Please understand that we may have additional
comments after reviewing your response to our comment.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision. Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.
Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that
* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
* the company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.
We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.
Please direct all questions relating to the above to James
Murphy, Petroleum Engineer, at (202) 942-2939. Direct all
correspondence to the following ZIP code: 20549-0405.
Sincerely,
H. Roger Schwall
Assistant Director
cc: via facsimile
Douglas Currault II, Esq.
Jones, Walker, Waechter
Poitevent, Carriere & Denegre, L.L.P
504-589-8412 (fax)
T. Richter
M.Duru
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McMoRan Exploration Co.
May 11, 2005
page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405
DIVISION OF
CORPORATION FINANCE
</TEXT>
</DOCUMENT>