SEC Company Response from SM Energy Co (SM) (CIK 0000893538) (SM) — Jun 2, 2015
SM Energy Co (SM) (CIK 0000893538)
Date: June 2, 2015 · CIK: 0000893538 · Accession: 0001104659-15-042848
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-203700
Letter
Via EDGAR Securities and Exchange Commission Division of Corporation Finance Washington, D.C. 20549 Attention: H. Roger Schwall as amended by Amendment No. 1 to Form S-4 filed on May 28, 2015 File No. 333-203700
Re: SM Energy Company Registration Statement on Form S-4 filed April 28, 2015
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 4:00 p.m. Eastern Time on June 4, 2015, 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 June 2, 2015 Via EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: H. Roger Schwall Re: SM Energy Company Registration Statement on Form S-4 filed April 28, 2015 as amended by Amendment No. 1 to Form S-4 filed on May 28, 2015 File No. 333-203700 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 4:00 p.m. Eastern Time on June 4, 2015, 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 W. 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]