SEC Comment Letter for Idaho Strategic Resources, Inc. (IDR) (CIK 0001030192) (IDR) — Jul 14, 2014
Idaho Strategic Resources, Inc. (IDR) (CIK 0001030192)
Date: July 14, 2014 · CIK: 0001030192 · Accession: 0000000000-14-035411
AI Filing Summary & Sentiment
Reasoning
Referenced dates: June 20, 2014
Letter
July 14 , 2014 Via E -mail Mr. Delbert Steiner Chief Executive Officer New Jersey Mining Company 201 N. Third Street Coeur d’Alene, ID 83814
Re: New Jersey Mining Company Amendment No. 3 to Registration Statement on Form 10 Filed July 2, 2014 Form 8 -K Filed June 17, 2014 File No. 000 -28837
Dear Mr. Steiner :
We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with in formation so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not b elieve our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.
Amendment No. 3 to Registration Statement on Form 10
1. We note your response to comment 4 in our letter dated June 20, 2014 . It is unclear why you believe the issuance of shares in 2013, whether or not they replaced previous ly-held shares, is not required to be disclosed pursuant to Item 701 of Regulation S -K. Please advise us of the details of the transaction, including the approximate number of shareholders involved.
Mr. Delbert Steiner New Jersey Mining Company July 14 , 2014 Page 2
Form 8 -K Filed June 17, 2014
Exhibit 99.2
2. We note your disclosure of economic indicators for the Juniper Lease and the McKinley Project on pages 11 and 18, respectively. Considering you have no mineral reserves, please tell us the basis for these estimates. We also note the disclos ure of projected income from the Juniper Lease on page 11 and projected net profit for the McKinley Project on page 18. Please provide us the basis for these projections in accordance with Item 10(b) of Regulation S -K.
Please contact Tiffany Posil a t (202) 551 -3589 or James Lopez at (202) 551 - 3536 with any questions.
Sincerely,
/s/ Pamela Howell
for
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July 14 , 2014 Via E -mail Mr. Delbert Steiner Chief Executive Officer New Jersey Mining Company 201 N. Third Street Coeur d’Alene, ID 83814 Re: New Jersey Mining Company Amendment No. 3 to Registration Statement on Form 10 Filed July 2, 2014 Form 8 -K Filed June 17, 2014 File No. 000 -28837 Dear Mr. Steiner : We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with in formation so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not b elieve our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Amendment No. 3 to Registration Statement on Form 10 1. We note your response to comment 4 in our letter dated June 20, 2014 . It is unclear why you believe the issuance of shares in 2013, whether or not they replaced previous ly-held shares, is not required to be disclosed pursuant to Item 701 of Regulation S -K. Please advise us of the details of the transaction, including the approximate number of shareholders involved. Mr. Delbert Steiner New Jersey Mining Company July 14 , 2014 Page 2 Form 8 -K Filed June 17, 2014 Exhibit 99.2 2. We note your disclosure of economic indicators for the Juniper Lease and the McKinley Project on pages 11 and 18, respectively. Considering you have no mineral reserves, please tell us the basis for these estimates. We also note the disclos ure of projected income from the Juniper Lease on page 11 and projected net profit for the McKinley Project on page 18. Please provide us the basis for these projections in accordance with Item 10(b) of Regulation S -K. Please contact Tiffany Posil a t (202) 551 -3589 or James Lopez at (202) 551 - 3536 with any questions. Sincerely, /s/ Pamela Howell for John Reynolds Assistant Director