SEC Company Response from SM Energy Co (SM) (CIK 0000893538) (SM) — May 16, 2014
SM Energy Co (SM) (CIK 0000893538)
Date: May 16, 2014 · CIK: 0000893538 · Accession: 0001104659-14-039669
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-194304
Letter
Via EDGAR Securities and Exchange Commission Division of Corporation Finance Attention: Mr. H. Roger Schwall as amended by Amendment No. 1 to Form S-4 filed on May 9, 2014 File No. 333-194304
Re: SM Energy Company Registration Statement on Form S-4 filed March 4, 2014
Dear Mr. Schwall:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, and the rules and regulations promulgated thereunder, SM Energy Company (the “Company”) respectfully requests that the effective date for the above-captioned registration statement on Form S-4 (the “Registration Statement”), be accelerated so that the Registration Statement will be declared effective at 12:00 p.m. Eastern Time on May 20, 2014, or as soon thereafter as is practicable.
In addition, the Company formally acknowledges that:
· Should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement.
· The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement.
· The Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please feel free to contact me at (303) 861-8140 with any questions or comments you may have.
Very truly yours,
SM ENERGY COMPANY
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CORRESP 1 filename1.htm May 16, 2014 Via EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Mr. H. Roger Schwall Re: SM Energy Company Registration Statement on Form S-4 filed March 4, 2014 as amended by Amendment No. 1 to Form S-4 filed on May 9, 2014 File No. 333-194304 Dear Mr. Schwall: Pursuant to Rule 461 under the Securities Act of 1933, as amended, and the rules and regulations promulgated thereunder, SM Energy Company (the “Company”) respectfully requests that the effective date for the above-captioned registration statement on Form S-4 (the “Registration Statement”), be accelerated so that the Registration Statement will be declared effective at 12:00 p.m. Eastern Time on May 20, 2014, or as soon thereafter as is practicable. In addition, the Company formally acknowledges that: · Should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement. · The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement. · The Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please feel free to contact me at (303) 861-8140 with any questions or comments you may have. Very truly yours, SM ENERGY COMPANY By: /s/ David Copeland Name: David W. Copeland Title: Executive Vice President, General Counsel and Corporate Secretary cc: Lucy Stark, Holland & Hart LLP [Signature Page to Acceleration Request Letter]