SEC Comment Letter for SILVER BULL RESOURCES, INC. (SVBL) (CIK 0001031093) (SVBL) — Nov 3, 2020
SILVER BULL RESOURCES, INC. (SVBL) (CIK 0001031093)
Date: Nov. 3, 2020 · CIK: 0001031093 · Accession: 0000000000-20-010429
AI Filing Summary & Sentiment
File numbers found in text: 001-33125
Letter
United States securities and exchange commission logo November 3, 2020 Christopher Richards Chief Financial Officer SILVER BULL RESOURCES, INC. 777 Dunsmuir Street Suite 1610 Vancouver, British Columbia V7Y 1K4 Re:SILVER BULL RESOURCES, INC. Preliminary Proxy Statement on Schedule 14A Filed October 23, 2020 File No. 001-33125 Dear Mr. Richards: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Preliminary Proxy Statement Filed October 23, 2020 About the Special Meeting Why is the Company seeking approval to increase the number of authorized shares of Silver Bull common stock?, page 5 1.We note that the proposed increase in the number of authorized shares is materially related to an option agreement dated as of August 12, 2020 and would enable the Company to issue shares pursuant to such agreement, disclosed in a Form 8-K filed on August 18, 2020. However, it does not appear that you have included the option agreement as an exhibit nor filed the option agreement as an exhibit to the Form 8-K in accordance with Item 1.01 of Form 8-K. Please amend your proxy statement to include the option agreement as an exhibit.
FirstName LastNameChristopher Richards Comapany NameSILVER BULL RESOURCES, INC. November 3, 2020 Page 2 FirstName LastName Christopher Richards SILVER BULL RESOURCES, INC. November 3, 2020 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844 or, in her absence, Loan Lauren Nguyen, Legal Branch Chief, at (202) 551-3642 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Brian Boonstra
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United States securities and exchange commission logo
November 3, 2020
Christopher Richards
Chief Financial Officer
SILVER BULL RESOURCES, INC.
777 Dunsmuir Street
Suite 1610
Vancouver, British Columbia V7Y 1K4
Re:SILVER BULL RESOURCES, INC.
Preliminary Proxy Statement on Schedule 14A
Filed October 23, 2020
File No. 001-33125
Dear Mr. Richards:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Preliminary Proxy Statement Filed October 23, 2020
About the Special Meeting
Why is the Company seeking approval to increase the number of authorized shares of Silver Bull
common stock?, page 5
1.We note that the proposed increase in the number of authorized shares is materially
related to an option agreement dated as of August 12, 2020 and would enable the
Company to issue shares pursuant to such agreement, disclosed in a Form 8-K filed on
August 18, 2020. However, it does not appear that you have included the option
agreement as an exhibit nor filed the option agreement as an exhibit to the Form 8-K in
accordance with Item 1.01 of Form 8-K. Please amend your proxy statement to include
the option agreement as an exhibit.
FirstName LastNameChristopher Richards
Comapany NameSILVER BULL RESOURCES, INC.
November 3, 2020 Page 2
FirstName LastName
Christopher Richards
SILVER BULL RESOURCES, INC.
November 3, 2020
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Please contact Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844 or, in her
absence, Loan Lauren Nguyen, Legal Branch Chief, at (202) 551-3642 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: Brian Boonstra