SEC Comment Letter for DYNARESOURCE, INC. (DYNR) (CIK 0001111741) (DYNR) — Jul 3, 2008
DYNARESOURCE, INC. (DYNR) (CIK 0001111741)
Date: July 3, 2008 · CIK: 0001111741 · Accession: 0000000000-08-033105
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 7010
May 28, 2008
via U.S. Mail and Facsimile
Mr. K.W. Diepholz President DynaResource, Inc. 5215 N. O’Connor Blvd., Suite 200 Irving, Texas 75039 Re: DynaResource, Inc. Registration Statement on Form 10 Filed May 14, 2008 File No. 0-53237 Dear Mr. Diepholz: This is to advise you that a preliminar y review of the above registration statement
indicates that it does not includ e all of the financial statem ents and supplementary data
required by Item 13 of Form 10. Specifically, the regist ration statement does not include a
report of an independent accountant. As a result, the registra tion statement fails in material
respects to comply with the requirements of Form 10. For this reason, we will not perform a
detailed examination of the registration statem ent and we will not is sue comments because
to do so would delay the review of other disclo sure documents that do not appear to contain
comparable deficiencies. You are advised that the registration st atement will become effective through
operation of law on July 14, 2008, and, if it becomes effect ive in its presen t form, we would
be required to consider what recommendation, if any, we should ma ke to the Commission.
We suggest that you cons ider submitting a substantiv e amendment correcting the
deficiencies or a request for withdrawal of the registratio n statement before it becomes
effective. With regard to the financial statements, you ma y contact Bob Carroll at (202)
551-3362 or Chris White at (2 02) 551-3461. Please contact John Madison at (202) 551-
3296, or Mellissa Duru at (202) 551-3757 if you have any other questions.
Sincerely,
H. Roger Schwall
Assistant Director
Cc: B. Carroll C. White M. Duru J. Madison