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SEC Comment Letter for GOLDEN EAGLE INTERNATIONAL INC (ADGO) (CIK 0000869531) — May 27, 2005

GOLDEN EAGLE INTERNATIONAL INC (ADGO) (CIK 0000869531)
Date: May 27, 2005 · CIK: 0000869531 · Accession: 0000000000-05-026297

AI Filing Summary & Sentiment

File numbers found in text: 000-23726

Date
May 6, 2005
Author
??
Form
UPLOAD
Company
GOLDEN EAGLE INTERNATIONAL INC (ADGO) (CIK 0000869531)

Letter

May 6, 2005 via facsimile and U.S. mail Mr. Terry C. Turner President, Chairman, and Chief Executive Officer 12401 South 450 East, Building D1 Salt Lake City, Utah 84020

Re: Golden Eagle International Inc. Form 10-K, filed April 15, 2005 File No. 000-23726

Dear Mr. Turner:

We have reviewed the above filing and have the following engineering comments. Our review has been limited to the areas identified below. Please provide us a response to the comments and include appropriate disclosure in future filings. 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 on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

Engineering Comments

General

1. Please number the filings` pages within EDGAR to expedite communications.

Business Development, page 5

2. Locate the mineral properties on the map found on page 6. Also locate the major roads, railroads, and pertinent cities to aid the average investor in locating the properties and accessing logistical & infrastructure requirements.

Activities at the Cangalli claims to generate production, page 9

3. Within the table clarify the gold production grade category. Does this category refer to grade per metric ton or is this the grade per cubic meter? Provide an in-place density estimate to convert cubic meters to metric tons (tonnes).

Efforts to Obtain Additional Production, page 15 & Buen Futuro Reserves, page 20

4. It is the staff`s position that prior to declaring reserves, the company should have obtained a "final" or "bankable" feasibility study, and employed the historic three-year average price for the economic analysis. In addition, the company should have submitted all necessary permits and authorizations, including environmental, to governmental authorities.

Supplementally provide the Cangalli Reserves report prepared by Carlos Thompson and Giovanni Viscarra, dated February 2004, as referenced on page 15 and the Buen Futuro Reserve Report prepared by Michael Biste, Ronald Atwood, and Hugo Aparacio, dated February 2004. Include production from these properties since publication and recent cutoff grade calculations. To minimize shipping and handling costs, this report may be sent on a CD-ROM.

Gold Bar Mill and Plant, page 22

5. Supplementally provide a copy of the fairness report by H. E. Dunham and Associates concerning the purchase of the Gold Bar mill. To minimize shipping and handling costs, this report may be sent on a CD-ROM.

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 amendments to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental 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 reviewed by the staff to be certain that they have provided all information investors require for an informed decision. Since the company and its management are in possession of all facts relating to the 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 George (Ken) Schuler, mining engineer, at (202) 824-5527 or, in his absence, Roger Baer, mining engineer, at (202) 942-2965, if you have questions regarding engineering comments. Please contact me at (202) 942-1870 with any other questions. Direct all correspondence to the following ZIP code: 20549-0405.

Sincerely,
H. Roger Schwall
Assistant Director
??

Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
									May 6, 2005

via facsimile and U.S. mail

Mr. Terry C. Turner
President, Chairman, and Chief Executive Officer
12401 South 450 East, Building D1
Salt Lake City, Utah  84020

	Re:	Golden Eagle International Inc.
		Form 10-K, filed April 15, 2005
		File No. 000-23726

Dear Mr. Turner:

      We have reviewed the above filing and have the following
engineering comments.  Our review has been limited to the areas
identified below.   Please provide us a response to the comments
and
include appropriate disclosure in future filings.  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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Engineering Comments

General

1. Please number the filings` pages within EDGAR to expedite
communications.

Business Development, page 5

2. Locate the mineral properties on the map found on page 6.  Also
locate the major roads, railroads, and pertinent cities to aid the
average investor in locating the properties and accessing
logistical
& infrastructure requirements.

Activities at the Cangalli claims to generate production, page 9

3. Within the table clarify the gold production grade category.
Does
this category refer to grade per metric ton or is this the grade
per
cubic meter?  Provide an in-place density estimate to convert
cubic
meters to metric tons (tonnes).

Efforts to Obtain Additional Production, page 15 & Buen Futuro
Reserves, page 20

4. It is the staff`s position that prior to declaring reserves,
the
company should have obtained a "final" or "bankable" feasibility
study, and employed the historic three-year average price for the
economic analysis.  In addition, the company should have submitted
all necessary permits and authorizations, including environmental,
to
governmental authorities.

Supplementally provide the Cangalli Reserves report prepared by
Carlos Thompson and Giovanni Viscarra, dated February 2004, as
referenced on page 15 and the Buen Futuro Reserve Report prepared
by
Michael Biste, Ronald Atwood, and Hugo Aparacio, dated February
2004.
Include production from these properties since publication and
recent
cutoff grade calculations.  To minimize shipping and handling
costs,
this report may be sent on a CD-ROM.

Gold Bar Mill and Plant, page 22

5. Supplementally provide a copy of the fairness report by H. E.
Dunham and Associates concerning the purchase of the Gold Bar
mill.
To minimize shipping and handling costs, this report may be sent
on a
CD-ROM.

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
amendments to expedite our review.  Please furnish a cover letter
with your amendment that keys your responses to our comments and
provides any requested supplemental 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 reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to the 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 George (Ken) Schuler, mining engineer, at
(202)
824-5527 or, in his absence, Roger Baer, mining engineer, at (202)
942-2965, if you have questions regarding engineering comments.
Please contact me at (202) 942-1870 with any other questions.
Direct
all correspondence to the following ZIP code:  20549-0405.

							Sincerely,

							H. Roger Schwall
							Assistant Director
??

??

??

??

Mr. Terry C. Turner
Golden Eagle International Inc.
May 6, 2005
Page 2

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>