Correspondence 0001193125-24-009298 from SAN JUAN BASIN ROYALTY TRUST (SJT) (CIK 0000319655) (SJT)
SAN JUAN BASIN ROYALTY TRUST (SJT) (CIK 0000319655)
Date: Jan. 17, 2024 · CIK: 0000319655 · Accession: 0001193125-24-009298
AI Filing Summary & Sentiment
File numbers found in text: 001-08032
Referenced dates: January 4, 2024
Letter
January 17, 2024
BY CERTIFIED MAIL
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Division of Corporation Finance
Office of Real Estate & Construction
Attention: Jeffrey Lewis
Kristina Marrone
Mayer Brown LLP
700 Louisiana Street
Suite 3400
Houston, Texas 77002-2730
Main Tel +1 713 238 3000
Main Fax +1 713 238 4888
www.mayerbrown.com
Robert F. Gray
Direct Tel (713) 238-2600
Direct Fax (713) 238-4600
rgray@mayerbrown.com
Re: San Juan Basin Royalty Trust
Form 10-K for the fiscal year ended December 31, 2022
Form 10-K/A for the fiscal year ended December 31, 2022
File No. 001-08032
Ladies and Gentlemen:
This letter is submitted on behalf of San Juan Basin Royalty Trust (the “Trust”) in response to comments raised by the Staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “SEC”) in the Staff’s letter to Mr. Ross Durr with the Trust, dated January 4, 2024. The responses to the Staff’s comments are set forth below, with each paragraph numbered to correspond to the numbered comments set forth in the letter. For your convenience, your comments have been reproduced below, together with the responses of the Company.
Form 10-K/A for the fiscal year ended December 31, 2022
Exhibit 32, page 1
1. We note your response to our prior comment and revised certification that was filed in the Form 10-K/A on December 11, 2023. As previously requested, please file a full amendment with certifications that are currently dated and refer to the Form 10-K/A.
Response:
In response, the Company will file a full amendment with the corrected certifications. The amendment will include the following explanatory note:
San Juan Basin Royalty Trust (the “Trust”) filed its Annual Report on Form 10-K for the fiscal year ended December 31, 2022 (the “Original 10-K”) with the Securities and Exchange Commission (“SEC”) on March 31, 2023. The Trust filed the Amendment No. 1 to the Original 10-K solely for the purpose of filing a revised certification required by Rule 13a-14(b) with the SEC on December 11, 2023. The Trust is now filing this Amendment No. 2 to the Original 10-K for the purpose of filing a full amendment with certifications that are currently dated.
Please direct your questions or additional comments to me by phone at 713-238-2600 or via email at rgray@mayerbrown.com. In addition, please provide via facsimile transmission any additional written comments you may have to me at 713-238-4600. Thank you for your assistance.
Very truly yours,
Robert F. Gray
Show Raw Text
CORRESP
1
filename1.htm
CORRESP
January 17, 2024
BY CERTIFIED MAIL
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Division of Corporation Finance
Office of Real Estate &
Construction
Attention: Jeffrey Lewis
Kristina Marrone
Mayer Brown LLP
700 Louisiana Street
Suite 3400
Houston, Texas 77002-2730
Main Tel +1 713 238 3000
Main Fax +1
713 238 4888
www.mayerbrown.com
Robert F. Gray
Direct Tel
(713) 238-2600
Direct Fax (713) 238-4600
rgray@mayerbrown.com
Re: San Juan
Basin Royalty Trust
Form 10-K for the fiscal year ended December 31, 2022
Form 10-K/A for the fiscal year ended December 31, 2022
File No. 001-08032
Ladies and Gentlemen:
This letter is submitted on behalf of San Juan Basin Royalty Trust (the “Trust”) in response to comments raised by the Staff (the
“Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “SEC”) in the Staff’s letter to Mr. Ross Durr with the Trust, dated January 4, 2024. The responses to the Staff’s
comments are set forth below, with each paragraph numbered to correspond to the numbered comments set forth in the letter. For your convenience, your comments have been reproduced below, together with the responses of the Company.
Form 10-K/A for the fiscal year ended December 31, 2022
Exhibit 32, page 1
1. We note your response to our
prior comment and revised certification that was filed in the Form 10-K/A on December 11, 2023. As previously requested, please file a full amendment with certifications that are currently dated and refer
to the Form 10-K/A.
Response:
In response, the Company will file a full amendment with the corrected certifications. The amendment will include the following explanatory
note:
San Juan Basin Royalty Trust (the “Trust”) filed its Annual Report on Form 10-K
for the fiscal year ended December 31, 2022 (the “Original 10-K”) with the Securities and Exchange Commission (“SEC”) on March 31, 2023. The Trust filed the Amendment No. 1
to the Original 10-K solely for the purpose of filing a revised certification required by Rule 13a-14(b) with the SEC on December 11, 2023. The Trust is now filing
this Amendment No. 2 to the Original 10-K for the purpose of filing a full amendment with certifications that are currently dated.
Please direct your questions or additional comments to me by phone at 713-238-2600 or via email at rgray@mayerbrown.com. In addition, please provide via facsimile transmission any additional written comments you may have to me at 713-238-4600. Thank you for your assistance.
Very truly yours,
Robert F. Gray
RFG