SEC Comment Letter for RUBICON MINERALS CORP (CIK 0001057791) — Oct 11, 2005
RUBICON MINERALS CORP (CIK 0001057791)
Date: Oct. 11, 2005 · CIK: 0001057791 · Accession: 0000000000-05-052033
AI Filing Summary & Sentiment
File numbers found in text: 001-31345
Referenced dates: September 9, 2005
Letter
October 7, 2005 Mr. David A. Adamson President and Chief Executive Officer Rubicon Minerals Corporation 1540-800 West Pender Street Vancouver, British Columbia V6C 2V6 Canada
Re: Rubicon Minerals Corporation Form 20-F for the Year Ended December 31, 2004 Filed March 15, 2005 File No. 001-31345 Supplemental Response Dated September 28, 2005
Dear Mr. Adamson:
We have reviewed your filings and have the following comment. We have limited our review of your filings to those issues we have addressed in our comments. Please provide a written response to our comment. Please be as detailed as necessary in your explanation. After reviewing this information, we may raise additional comments. The page number referenced below correspond to those utilized in the Form 20-F.
Form 20-F for the Year Ended December 31, 2004
Consolidated Financial Statements, page 65
Differences between Canadian and United States Generally Accepted Accounting Principles, page 86
1. We note your response to our prior comment number one in our letter dated September 9, 2005. We understand you considered CICA Emerging Issues Committee Abstract #126 and FASB Statement No. 144 for Canadian and U.S. GAAP reporting purposes, respectively. It is unclear to us how you were able to conclude that the estimated future cash flows are insufficient to recover carrying amounts of the property for reporting under U.S. GAAP if you do not have a basis for preparing a projection of the estimated future net cash flow from the property, which is one of the factors mentioned in the Abstract #126. Please elaborate on how you applied FASB Statement No. 144 and the Abstract #126.
Closing Comments
Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please understand that we may have additional comments after reviewing your response to our comment.
You may contact Yong Choi at (202) 551-3758 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3684 with any other questions.
Sincerely,
April Sifford
Branch Chief
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
October 7, 2005
Mr. David A. Adamson
President and Chief Executive Officer
Rubicon Minerals Corporation
1540-800 West Pender Street
Vancouver, British Columbia V6C 2V6
Canada
Re: Rubicon Minerals Corporation
Form 20-F for the Year Ended December 31, 2004
Filed March 15, 2005
File No. 001-31345
Supplemental Response Dated September 28, 2005
Dear Mr. Adamson:
We have reviewed your filings and have the following
comment.
We have limited our review of your filings to those issues we have
addressed in our comments. Please provide a written response to
our
comment. Please be as detailed as necessary in your explanation.
After reviewing this information, we may raise additional
comments.
The page number referenced below correspond to those utilized in
the
Form 20-F.
Form 20-F for the Year Ended December 31, 2004
Consolidated Financial Statements, page 65
Differences between Canadian and United States Generally Accepted
Accounting Principles, page 86
1. We note your response to our prior comment number one in our
letter
dated September 9, 2005. We understand you considered CICA
Emerging
Issues Committee Abstract #126 and FASB Statement No. 144 for
Canadian
and U.S. GAAP reporting purposes, respectively. It is unclear to
us
how you were able to conclude that the estimated future cash flows
are
insufficient to recover carrying amounts of the property for
reporting
under U.S. GAAP if you do not have a basis for preparing a
projection
of the estimated future net cash flow from the property, which is
one
of the factors mentioned in the Abstract #126. Please elaborate
on
how you applied FASB Statement No. 144 and the Abstract #126.
Closing Comments
Please respond to this comment within 10 business days or
tell
us when you will provide us with a response. Please understand
that
we may have additional comments after reviewing your response to
our
comment.
You may contact Yong Choi at (202) 551-3758 if you have
questions regarding comments on the financial statements and
related
matters. Please contact me at (202) 551-3684 with any other
questions.
Sincerely,
April Sifford
Branch Chief
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Mr. Adamson
Rubicon Minerals Corporation
October 7, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010
</TEXT>
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