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SEC Comment Letter for RB GLOBAL INC. (RBA) (CIK 0001046102) (RBA) — Feb 13, 2013

RB GLOBAL INC. (RBA) (CIK 0001046102)
Date: Feb. 13, 2013 · CIK: 0001046102 · Accession: 0000000000-13-008583

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
February 13, 2013
Author
/s/ Patrick Gilmore
Form
UPLOAD
Company
RB GLOBAL INC. (RBA) (CIK 0001046102)

Letter

February 13, 2013 Via E -mail Robert A. McLeod Chief Financial Officer Ritchie Bros. Auctioneers Incorporated 9500 Glenlyon Parkway Burnaby, B.C. Canada V5J 0C6

Re: Ritchie Bros. Auctioneers Incorporated Form 40-F for the Fiscal Year Ended December 31, 2011 Filed February 28, 2012 File No. 001 -13425

Dear Mr. McLeod :

We have completed our review of your filing. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or 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 secur ities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules requ ire.

Sincerely,
/s/ Patrick Gilmore

Show Raw Text
February 13, 2013

Via E -mail
Robert A. McLeod
Chief Financial Officer
Ritchie Bros. Auctioneers Incorporated
9500 Glenlyon Parkway
Burnaby, B.C. Canada V5J 0C6

Re: Ritchie Bros. Auctioneers Incorporated
 Form 40-F for the Fiscal Year Ended December 31, 2011
Filed February 28, 2012
File No. 001 -13425

Dear Mr. McLeod :

We have completed our review of your filing.  We remind you that our comments or
changes to disclosure in response  to our comments do not foreclose the Commission from taking
any action with respect to the company or 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 secur ities laws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing  to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules requ ire.

Sincerely,

 /s/ Patrick Gilmore

Patrick Gilmore
Accounting Branch Chief