SEC Comment Letter for Coeur Mining, Inc. (CDE) (CIK 0000215466) (CDE) — Oct 12, 2018
Coeur Mining, Inc. (CDE) (CIK 0000215466)
Date: Oct. 12, 2018 · CIK: 0000215466 · Accession: 0000000000-18-032121
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File numbers found in text: 001-08641
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October 12, 2018
Peter Mitchell
Senior Vice President and Chief Financial Officer
Coeur Mining, Inc.
104 S. Michigan Ave. Suite 900
Chicago, IL 60603
Re:Coeur Mining, Inc.
Form 10-K
Filed February 7, 2018
File No. 001-08641
Dear Mr. Mitchell:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. 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 business days by providing the requested
information or advise 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 your response to these comments, we may have additional comments.
FORM 10-K
Proven and Probable Reserves, page 30
1.Mineralized materials are disclosed for your Silvertip property. Please forward to our
engineer as supplemental information and not as part of your filing, your information that
establishes the quantity and quality of your mineralized materials, as required by Industry
Guide 7(c). The information requested includes, but is not limited to:
•Property and geologic maps
•Description of your sampling and assaying procedures
•Drill-hole maps showing drill intercepts
FirstName LastNamePeter Mitchell
Comapany NameCoeur Mining, Inc.
October 12, 2018 Page 2
FirstName LastNamePeter Mitchell
Coeur Mining, Inc.
October 12, 2018
Page 2
•Representative geologic cross-sections and drill logs
•Description and examples of your cut-off calculation procedures
•Cutoff grades used for each category of your reserves and resources
•Justifications for the drill hole spacing used to classify and segregate proven and
probable reserves
•A detailed description of your procedures for estimating reserves
•Copies of any pertinent engineering or geological reports, and executive summaries of
feasibility studies or mine plans which including the cash flow analyses
•A detailed permitting and government approval schedule for the project, particularly
identifying the primary environmental or construction approval(s) and your current
location on that schedule.
To minimize the transfer of paper, please provide the requested information on a CD or a
flash drive, formatted as Adobe PDF files and provide the name and phone number for a
technical person our engineer may call, if he has technical questions about your reserves.
In the event your company desires the return of this supplemental material, please make a
written request with the letter of transmittal and include a pre-paid, pre-addressed shipping
label to facilitate the return of the supplemental information. Please note that you may
request the return of this information pursuant to the provisions of Rule 12b-4 of the
Exchange Act.
If there are any questions concerning the above request, please phone Mr. George K.
Schuler, Mining Engineer at (202) 551-3718.
Mineralized Material, page 32
2.We note your disclosure of mineralized materials, which appear to be the sum of your
measured, indicated, and inferred resources as indicated by a comparison of your filing to
your website and technical reports. Mineralized material does not include the tonnage and
grade estimated by using geologic inference, which are sometimes classed as “inferred” or
“possible” by some evaluators. Please restate your mineralized materials without the
inferred resources.
FirstName LastNamePeter Mitchell
Comapany NameCoeur Mining, Inc.
October 12, 2018 Page 3
FirstName LastName
Peter Mitchell
Coeur Mining, Inc.
October 12, 2018
Page 3
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact George K. Schuler at (202) 551-3718 or Pam Howell at (202) 551-3357
with any questions.
Sincerely,
Division of Corporation Finance
Office of Beverages, Apparel and
Mining