SEC Comment Letter for SM Energy Co (SM) (CIK 0000893538) (SM) — Jan 7, 2013
SM Energy Co (SM) (CIK 0000893538)
Date: Jan. 7, 2013 · CIK: 0000893538 · Accession: 0000000000-13-000875
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January 7, 2013
Via E -mail
A. Wade Pursell
Executive Vice President and Chief Financial Officer
SM Energy Company
1775 Sherman Street, Suite 1200
Denver , Colorado 80203
Re: SM Energy Company
Form 10-K for Fiscal Year Ended
December 31, 2011
Filed February 23, 2012
File No. 001 -31539
Dear Mr. Pursell :
We have completed our review of your filing . We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or 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 Un ited States. We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the
information the Securities Exchange Act of 1934 and all applicable rules require.
Sincerely,
/s/ Ethan Horowitz
Ethan Horowitz
Branch Chief