SEC Company Response from Idaho Strategic Resources, Inc. (IDR) (CIK 0001030192) (IDR) — Sep 8, 2011
Idaho Strategic Resources, Inc. (IDR) (CIK 0001030192)
Date: Sept. 8, 2011 · CIK: 0001030192 · Accession: 0001062993-11-003631
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-28837
Referenced dates: June 24, 2010
Letter
Pre 14A Filed July 15, 2011 File No. 000-28837
Re: New Jersey Mining Company
Dear Ms. Ravitz:
The amended Schedule 14A is filed in response to the Staff’s comment letter of August 10, 2011. The comments have been addressed as follows:
Comment 1: The outstanding comments in the Staff’s letter dated June 24, 2010, on the Company’s preliminary proxy statement filed on June 3, 2010, have been resolved as follows on the Amended Schedule 14A filed on August 24, 2011.
1.
Board of Directors of the Company
Additional requested disclosure has been added to the biographies of each director on pages 9-10.
2.
Information Concerning the Board of Directors
A new section entitled “Board Leadership Structure” has been added on page 18.
3.
Nominating Committee Consideration of Diversity
This issue has been addressed on page 17 in the next to last sentence of the “Nominating Committee” disclosure section.
P.O. Box 1019 • Kellogg, Idaho 83837 • Phone (208) 783-1032 • www.newjerseymining.com
Ms. Amanda Ravitz Securities and Exchange Commission
September 8, 2011 Page 2
4.
Director Compensation
Footnote 2 to the Compensation of Directors table has been revised to disclose that the stock awards have been valued in accordance with FASB Accounting Standards Codification Topic on page 18.
5.
Legal Proceedings
The required disclosure has been revised in the Legal proceedings section found on page 19.
6.
Summary Compensation Table
Footnote 1 has been revised to disclose that the stock awards have been valued in accordance with FASB Accounting Standards Codification Topic 718 on page 21.
Comment 2: Per Mr. Jeffery Jaramillo’s correspondence of August 29, 2011, it is our understanding that the Staff has completed its review of our response to Staff comments on the Form 10K for the fiscal year ended December 31, 2010, and the Form 10Q for the period ended March 31, 2011, and all comments have been addressed and resolved.
The Company acknowledges 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.
Very truly yours,
NEW JERSEY MINING COMPANY
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CORRESP
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filename1.htm
New Jersey Mining Company: Correspondence - Filed by newsfilecorp.com
September 8, 2011
Ms. Amanda Ravitz
Assistant Director
Division of
Corporate Finance
Securities and Exchange Commission
Washington, D.C.
20549
Re:
New Jersey Mining Company
Pre 14A
Filed July 15, 2011
File No. 000-28837
Dear Ms. Ravitz:
The amended Schedule 14A is filed in response to the Staff’s
comment letter of August 10, 2011. The comments have been addressed as
follows:
Comment 1: The outstanding comments in the Staff’s
letter dated June 24, 2010, on the Company’s preliminary proxy statement filed
on June 3, 2010, have been resolved as follows on the Amended Schedule 14A filed
on August 24, 2011.
1.
Board of Directors of the Company
Additional requested disclosure has been added to the
biographies of each director on pages 9-10.
2.
Information Concerning the Board of
Directors
A new section entitled “Board Leadership Structure” has
been added on page 18.
3.
Nominating Committee Consideration of
Diversity
This issue has been addressed on page 17 in the next to
last sentence of the “Nominating Committee” disclosure
section.
P.O. Box 1019 • Kellogg, Idaho 83837 • Phone (208) 783-1032 •
www.newjerseymining.com
Ms. Amanda Ravitz
Securities and Exchange Commission
September 8, 2011
Page 2
4.
Director Compensation
Footnote 2 to the Compensation of Directors table has
been revised to disclose that the stock awards have been valued in
accordance with FASB Accounting Standards Codification Topic on page
18.
5.
Legal Proceedings
The required disclosure has been revised in the Legal
proceedings section found on page 19.
6.
Summary Compensation Table
Footnote 1 has been revised to disclose that the stock
awards have been valued in accordance with FASB Accounting Standards
Codification Topic 718 on page 21.
Comment 2: Per Mr. Jeffery Jaramillo’s correspondence of
August 29, 2011, it is our understanding that the Staff has completed its review
of our response to Staff comments on the Form 10K for the fiscal year ended
December 31, 2010, and the Form 10Q for the period ended March 31, 2011, and all
comments have been addressed and resolved.
The Company acknowledges 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.
Very truly yours,
NEW JERSEY MINING COMPANY
By: /s/Fred W.
Brackebusch
Fred W. Brackebusch,
President
P.O. Box 1019 • Kellogg, Idaho 83837 • Phone (208) 783-1032 •
www.newjerseymining.com