SEC Comment Letter for CORAL GOLD RESOURCES, LTD. (CIK 0000813639) — Mar 3, 2005
CORAL GOLD RESOURCES, LTD. (CIK 0000813639)
Date: March 3, 2005 · CIK: 0000813639 · Accession: 0000000000-05-010043
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405
DIVISION OF
CORPORATION FINANCE
March 3, 2005
via U.S. mail via facsimile
Matt Wayrynen Matt Wayrynen
Chief Executive Officer and Chief Executive
Officer
and
Principal Financial Officer Principal Financial
Officer
Coral Gold Corp. (604) 682-3600
455 Granville Street, Suite 400
Vancouver, British Columbia V6C 1T1
Canada
Re: Coral Gold Corp.
Form 20-F filed August 16, 2004
File No. 0-15688
Dear Mr. Wayrynen:
We have reviewed your filing and have the following
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
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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/A filed February 24, 2005
Accounting Comments
Explanatory Note
1. Expand this disclosure to include the reasons why you are
filing
an amended Form 20-F. As currently phrased, investors may believe
that you filed the amendment primarily or only to reflect the name
change.
Financial Statements
2. We note your responses to prior comments 7 and 9 and are unable
to
agree with your conclusions. Please refer to Industry Guide 7,
paragraph (a)(4)(i), which states that the exploration stage
"includes all issuers engaged in the search for mineral deposits
(reserves) which are not in either the development or production
stage." Also refer to the requirements of FAS 7 for U.S. GAAP,
which
requires that companies that have not had significant revenue
provide
cumulative revenues and expenses from inception. We reissue prior
comments 7 and 9 in their entirety.
3. We note your response to prior comment 8. It appears that you
should estimate the fair value of your reclamation liability based
on
the best information available to you and revise your financial
statements to recognize this liability in the period when that
information became available. We note that you have been able to
determine that your $406,000 bond will be sufficient to cover
these
expenses. We reissue prior comment 8. Refer to CICA 3110 for
Canadian GAAP and FAS 143 for U.S. GAAP.
4. We note your response to prior comment 11. Please send to us a
schedule of your equipment and amortization for the years
presented
in your filing. We note that you had equipment valued at $3,419
at
the end of 2003. Thus, it does not appear that most of these
assets
were purchased at the end of 2004, as you indicate in your
response.
5. We note your response to prior comment 12. It appears that the
assets that you are capitalizing for U.S. GAAP purposes would
likely
be insupportable under FAS 144 prior to determining the existence
of
a commercially minable deposit. As such, it appears that they
should
have been expensed when incurred. Please amend your filing to
correct your U.S. GAAP reconciliations.
Engineering Comments
General
6. We note on page 17 your disclosure that Mr. McCusker prepared a
technical report for the Robertson property, and as such is
considered an expert under SEC rules. Supplementally provide a
written consent from any experts whose name you cite and whose
work
you incorporate into your document. These consents should concur
with the summary of the report contained in the document and agree
to
being named as an expert.
7. In the middle of page 41, you use the term "ore bodies." Under
Industry Guide 7, the term "ore body" is treated to mean the same
as
the term "reserve." Please remove the term "ore body" from this
section as it is currently used.
Please respond to this comment within 10 business days or
tell
us when you will provide us with a response. In your
correspondence,
please provide any requested supplemental information. Please
file
your correspondence on EDGAR. Please understand that we may have
additional comments after reviewing your response to our comment.
You may contact Sandy Eisen at 202-942-1805 or Kimberly
Calder
at 202-942-1879 if you have questions regarding comments on the
financial statements and related matters. Please contact Roger
Baer
at 202-942-2965 regarding engineering comments. Please contact me
at
202-942-1870 with any other questions.
Sincerely,
H. Roger Schwall
Assistant Director
cc: Sandy Eisen
Kimberly Calder
Roger Baer
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Coral Gold Corp.
March 3, 2005
page 3
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