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SEC Comment Letter for EXPLORATION CO OF DELAWARE INC (CIK 0000313395) — Aug 31, 2005

EXPLORATION CO OF DELAWARE INC (CIK 0000313395)
Date: Aug. 31, 2005 · CIK: 0000313395 · Accession: 0000000000-05-045164

AI Filing Summary & Sentiment

Referenced dates: August 4, 2005, July 12, 2005, July 25, 2005

Date
August 31, 2005
Author
Jill S. Davis
Form
UPLOAD
Company
EXPLORATION CO OF DELAWARE INC (CIK 0000313395)

Letter

August 31, 2005 Mr. P. Mark Stark Chief Financial Officer The Exploration Company of Delaware, Inc. 500 North Loop 1604 East, Suite 250 San Antonio, Texas 78232

Re: The Exploration Company of Delaware, Inc. Form 10-K for Fiscal Year Ended December 31, 2004 Filed March 16, 2005 Forms 10-Q for Fiscal Quarters Ended March 31, 2005 and June 30, 2005 Filed May 10, 2005 and August 9, 2005 Response Letters Dated July 25, 2005 and August 18, 2005 File No. 0-09120

Dear Mr. Stark:

We have reviewed your response letter and have the following comment. Please provide a written response to our comment. Please be as detailed as necessary in your explanation. In our comment, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.

Form 10-K for the Fiscal Year Ended December 31, 2004

Note A - Summary of Significant Accounting Policies, page F-7

Oil and Gas Properties, page F-7

1. We have reviewed your response to comment 11 included in our letter dated July 12, 2005 and comment one included in our letter dated August 4, 2005. Please expand your policy disclosure to incorporate the information provided in these responses. In this regard, clearly explain the manner by which you utilize the 3-D seismic data, the criteria used to determine if these costs represent development versus exploration costs and how you account for these costs. Closing Comments

Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your response to our comment and provides any requested information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your response to our comment.

You may contact Regina Balderas, Staff Accountant, at (202) 551-3722 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551- with any other questions.

Sincerely,
Jill S. Davis
Branch Chief

Show Raw Text
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<TEXT>
								August 31, 2005

Mr. P. Mark Stark
Chief Financial Officer
The Exploration Company of Delaware, Inc.
500 North Loop 1604 East, Suite 250
San Antonio, Texas  78232

	Re:	The Exploration Company of Delaware, Inc.
		Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 16, 2005
		Forms 10-Q for Fiscal Quarters Ended
      March 31, 2005 and June 30, 2005
      Filed May 10, 2005 and August 9, 2005
      Response Letters Dated July 25, 2005 and August 18, 2005
		File No. 0-09120

Dear Mr. Stark:

      We have reviewed your response letter and have the following
comment.  Please provide a written response to our comment.
Please
be as detailed as necessary in your explanation.  In our comment,
we
may ask you to provide us with information so we may better
understand your disclosure.  After reviewing this information, we
may
raise additional comments.

Form 10-K for the Fiscal Year Ended December 31, 2004

Note A - Summary of Significant Accounting Policies, page F-7

Oil and Gas Properties, page F-7

1. We have reviewed your response to comment 11 included in our
letter dated    July 12, 2005 and comment one included in our
letter
dated August 4, 2005.   Please expand your policy disclosure to
incorporate the information provided in these responses.  In this
regard, clearly explain the manner by which you utilize the 3-D
seismic data, the criteria used to determine if these costs
represent
development versus exploration costs and how you account for these
costs.
Closing Comments

       Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
letter
that keys your response to our comment and provides any requested
information.  Detailed letters greatly facilitate our review.
Please
understand that we may have additional comments after reviewing
your
response to our comment.

      You may contact Regina Balderas, Staff Accountant, at (202)
551-3722 if you have questions regarding comments on the financial
statements and related matters.  Please contact me at (202) 551-
3683
with any other questions.

								Sincerely,

								Jill S. Davis
								Branch Chief

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Mr. P. Mark Stark
The Exploration Company of Delaware, Inc.
August 31, 2005
page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

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