SEC Company Response from SILVER BULL RESOURCES, INC. (SVBL) (CIK 0001031093) (SVBL) — Nov 5, 2020
SILVER BULL RESOURCES, INC. (SVBL) (CIK 0001031093)
Date: Nov. 5, 2020 · CIK: 0001031093 · Accession: 0001079973-20-000930
AI Filing Summary & Sentiment
File numbers found in text: 001-33125
Referenced dates: November 3, 2020
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CORRESP
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Correspondence
Brian Boonstra
303.892.7348
brian.boonstra@dgslaw.com
November 5, 2020
Via EDGAR and Federal Express
Ms. Anuja A. Majmudar
Attorney-Advisor
Division of Corporation Finance
Office of Energy & Transportation
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Re: Silver Bull Resources, Inc.
Preliminary Proxy Statement on Schedule 14A
Filed October 23, 2020
File No. 001-33125
Dear Ms. Majmudar:
On
behalf of Silver Bull Resources, Inc. (“Silver Bull” or the “Company”), set forth below
is the response of the Company to the comment received by the Staff of the Securities and Exchange Commission contained in the
letter dated November 3, 2020 regarding the above-referenced filing.
For
ease of reference, the text of the Staff’s comment is reproduced in bold-face type below, followed by the Company’s
response.
Comment 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.
Response:
As discussed with the Staff, the Company has filed the option agreement with Copperbelt AG and Dostyk LLP, dated as of August 12,
2020 (the “Copperbelt Option Agreement”), as an exhibit to an amendment to the Company’s current report
on Form 8-K filed on August 18, 2020. In addition, the Company will incorporate by reference the full text of the Copperbelt
Option Agreement into the Company’s definitive proxy statement on Schedule 14A.
* * * * *
Should
you have additional questions or comments, please contact the undersigned at (303) 892-7348.
Sincerely,
/s/ Brian Boonstra
Brian Boonstra
for
Davis
Graham & Stubbs LLP
cc: Christopher Richards, Silver
Bull Resources, Inc.