SEC Comment Letter for Coeur Mining, Inc. (CDE) (CIK 0000215466) (CDE) — Feb 7, 2013
Coeur Mining, Inc. (CDE) (CIK 0000215466)
Date: Feb. 7, 2013 · CIK: 0000215466 · Accession: 0000000000-13-007229
AI Filing Summary & Sentiment
Reasoning
Letter
February 6, 2013 Via E -mail Mr. Mitchell J. Krebs Chief Executive Officer Coeur d’Alene Mines Corporation 505 Front Avenue Coeur d’Alene, I D 83814
Re: Coeur d’Alene Mines Corporation Form 10 -K for Fiscal Year Ended December 31, 2011 Filed February 23, 2012 Response dated January 24 , 2012 File No. 001 -08641
Dear Mr. Krebs :
We have reviewed your response and have the following comment . In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information , or by advising us when you will provide the requested response. If you d o not believe our comment applies to your facts and circumstances, or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to this comment , we may have additional comments.
Form 10 -K for Fiscal Year Ended December 31, 2011
Management’s Discussion and Analysis of Financial Condition and Results of Operations, page Reconciliation of Non -GAAP Cash Costs to GAAP Production Costs, page 53
1. We note your response to our prior comment 5. We also note the significant effect of by - product credits to your silver cost per ounce and cash cost per ounce measures computed using gold as a by-product. Accordingly, p lease modify your computation of these measures for the Palmarejo and Rochester mines so as not to include gold as a by -product credit. Please also expand your disclosure to include the significant assumptions underly ing your computation. In your response, tell us how you intend to present these measures in future filings.
Mr. Mitchell J. Krebs Coeur d’ Alene Mines Corporation February 6, 201 3 Page 2
You may contact James Giugliano at (202) 551 -3319, or Brian Bhandari at (202) 551 - 3390, if you have questions regarding comments on the financia l statements and related matters. You may contact George Schuler, Mining Engineer, at (202) 551 -3718 with questions about engineering comments. Please contact me at (202) 551 -3871 with any other questions.
Sincerely,
/s/Tia L. Jenkins
Show Raw Text
February 6, 2013
Via E -mail
Mr. Mitchell J. Krebs
Chief Executive Officer
Coeur d’Alene Mines Corporation
505 Front Avenue
Coeur d’Alene, I D 83814
Re: Coeur d’Alene Mines Corporation
Form 10 -K for Fiscal Year Ended December 31, 2011
Filed February 23, 2012
Response dated January 24 , 2012
File No. 001 -08641
Dear Mr. Krebs :
We have reviewed your response and have the following comment . In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to this letter within ten business days by amending your filing, by
providing the requested information , or by advising us when you will provide the requested
response. If you d o not believe our comment applies to your facts and circumstances, or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to this comment , we may have additional comments.
Form 10 -K for Fiscal Year Ended December 31, 2011
Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
45
Reconciliation of Non -GAAP Cash Costs to GAAP Production Costs, page 53
1. We note your response to our prior comment 5. We also note the significant effect of by -
product credits to your silver cost per ounce and cash cost per ounce measures computed
using gold as a by-product. Accordingly, p lease modify your computation of these
measures for the Palmarejo and Rochester mines so as not to include gold as a by -product
credit. Please also expand your disclosure to include the significant assumptions
underly ing your computation. In your response, tell us how you intend to present these
measures in future filings.
Mr. Mitchell J. Krebs
Coeur d’ Alene Mines Corporation
February 6, 201 3
Page 2
You may contact James Giugliano at (202) 551 -3319, or Brian Bhandari at (202) 551 -
3390, if you have questions regarding comments on the financia l statements and related matters.
You may contact George Schuler, Mining Engineer, at (202) 551 -3718 with questions about
engineering comments. Please contact me at (202) 551 -3871 with any other questions.
Sincerely,
/s/Tia L. Jenkins
Tia L. Jenkins
Senior Assistant Chief Accountan t
Office of Beverages, Apparel, and
Mining