SEC Comment Letter for SAMEX MINING CORP (CIK 0000766504) — Jul 18, 2005
SAMEX MINING CORP (CIK 0000766504)
Date: July 18, 2005 · CIK: 0000766504 · Accession: 0000000000-05-036783
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July 18, 2005
Mr. Larry D. McLean
Chief Financial Officer
Samex Mining Corp.
#301 - 32920 Ventura Avenue
Abbotsford, British Columbia, Canada V2S 6J3
Re: Samex Mining Corp.
Form 20-F for Fiscal Year Ended November 30, 2004
Filed May 31, 2005
File No. 0-13391
Dear Mr. McLean:
We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our 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 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 numbers listed at
the
end of this letter.
Form 20-F for the year ended November 30, 2004
1. We note that your filing includes an auditor`s report relating
to
your financial statements as of November 30, 2004, and for the
year
then ended.
Our rules require that an audit report be included for all periods
presented. In your case, this would include financial statements
as
of November 30, 2003, and for the periods ended November 30, 2003;
November 30, 2002; and inception to date.
Please amend your filing to include your prior auditor`s report
relating to these prior periods.
Closing Comments
As appropriate, please amend your filing and respond to
these
comments within 10 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
Division
of Corporation Finance in our review of your filing or in response
to
our comments on your filing.
You may contact Sandy Eisen at (202) 551-3864 if you have
questions regarding comments on the financial statements and
related
matters. Please contact me at (202) 551-3684 with any other
questions."
Sincerely,
April Sifford
Branch Chief
cc: Sandy Eisen
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Mr. Larry D. McLean
Samex Mining Corp.
July 18, 2005
page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, N.E.
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010
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