SEC Comment Letter for Coeur Mining, Inc. (CDE) (CIK 0000215466) (CDE) — Mar 7, 2006
Coeur Mining, Inc. (CDE) (CIK 0000215466)
Date: March 7, 2006 · CIK: 0000215466 · Accession: 0000000000-06-011281
AI Filing Summary & Sentiment
Reasoning
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION 100 F Str eet, NE WASHINGTON, D.C. 20549-7010 DIVISION OF CORP ORA TION FINANCE MAIL STOP 7010 March 7, 2006 Mr. James A. Sabala Chief Financial Officer Coeur d’Alene Mines Corporation 505 Front Ave., P.O. Box “I” Coeur d’Alene, ID 83816
Re: Coeur d’Alene Mines Corporation Item 4.02 Form 8-K Filed March 2, 2006 File No. 1-8641
Dear Mr. Sabala:
We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with more information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
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 filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone number listed at the end of this letter.
Item 4.02 Form 8-K filed March 2, 2006
1. Please tell us if your certifying officers have reconsidered the effect on the adequacy of your disclosure controls and procedures as of the end of the period covered by your Form 10-Q for the quarter ended March 31, 2005 in light of the error you have disclosed. Additionally, tell us what effect the error had on your
Mr. Jam es A. Sabala Coeur d’Alene Mines Corporation March 7, 2006 Page 2
current evaluation of disclosure controls and procedures as of your fiscal year ended December 31, 2005.
2. Please support your conclusion that you should not file an amended Form 10-Q for the quarter ended March 31, 2005 given your disclosure that “the interim financial statements previously set forth in the Company’s Quarterly Report on Form 10-Q for the quarter ended March 31, 2005 should no longer be relied upon.”
As appropriate, please amend your filing and respond to these comments within five business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment 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.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments 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 Di vision of Corporation Finance in our review of your filing or in response to our comments on your filing.
If you have any questions, please call Jennifer Goeken at (202) 551-3721.
Mr. James A. Sabala Coeur d’Alene Mines Corporation March 7, 2006 Page 3
S i n c e r e l y ,
Jill S. Davis B r a n c h C h i e f
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Str eet, NE
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORP ORA TION FINANCE
MAIL STOP 7010
March 7, 2006
Mr. James A. Sabala
Chief Financial Officer
Coeur d’Alene Mines Corporation
505 Front Ave., P.O. Box “I”
Coeur d’Alene, ID 83816
Re: Coeur d’Alene Mines Corporation
Item 4.02 Form 8-K
Filed March 2, 2006
File No. 1-8641
Dear Mr. Sabala:
We have reviewed your filing and have the following comments. Where
indicated, we think you should revise your document in response to these comments. If
you disagree, we will consider your explanation as to why our comment is inapplicable
or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with more information so we may
better understand your disclosure. After reviewing this information, we may raise
additional comments.
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 filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone number listed at the end of this letter.
Item 4.02 Form 8-K filed March 2, 2006
1. Please tell us if your certifying officers have reconsidered the effect on the adequacy of your disclosure controls and procedures as of the end of the period
covered by your Form 10-Q for the quarter ended March 31, 2005 in light of the
error you have disclosed. Additionally, tell us what effect the error had on your
Mr. Jam es A. Sabala
Coeur d’Alene Mines Corporation
March 7, 2006
Page 2
current evaluation of disclosure controls and procedures as of your fiscal year ended December 31, 2005.
2. Please support your conclusion that you should not file an amended Form 10-Q for the quarter ended March 31, 2005 given your disclosure that “the interim
financial statements previously set forth in the Company’s Quarterly Report on
Form 10-Q for the quarter ended March 31, 2005 should no longer be relied upon.”
As appropriate, please amend your filing and respond to these comments within
five business days or tell us when you will provide us with a response. You may wish to
provide us with marked copies of the amendment to expedite our review. Please furnish
a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review.
Please understand that we may have additional comments after reviewing your
amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under
the Securities Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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.
In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments 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 Di vision of Corporation Finance in our review
of your filing or in response to our comments on your filing.
If you have any questions, please call Jennifer Goeken at (202) 551-3721.
Mr. James A. Sabala
Coeur d’Alene Mines Corporation
March 7, 2006
Page 3
S i n c e r e l y ,
Jill S. Davis
B r a n c h C h i e f