SEC Comment Letter for DYNARESOURCE, INC. (DYNR) (CIK 0001111741) (DYNR) — Nov 21, 2012
DYNARESOURCE, INC. (DYNR) (CIK 0001111741)
Date: Nov. 21, 2012 · CIK: 0001111741 · Accession: 0000000000-12-063414
AI Filing Summary & Sentiment
File numbers found in text: 000-30371
Referenced dates: October 31, 2012
Letter
November 2 1, 2012 Via E-mail K.W. Diepholz Chairman and Chief Executive Officer DynaResource, Inc. 222 W. Las Colinas Boulevard Suite 744 East Tower Irving, Texas 75039
Re: DynaResource, Inc. Form 10-K for Fiscal Year Ended December 31, 2011 Filed April 2, 2012 Response dated November 14, 2012 File No. 000-30371
Dear Mr. Diepholz :
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 this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will pr ovide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.
Form 10 -K for Fiscal Year Ended December 31
General
1. We note your response to comments 1, 2, and 5 from our letter dated October 31, 2012. As a company incorpora ted in Delaware, only proven and probable reserves may be disclosed in filings with the United States Securities and Exchange Commission. The exemption to which you refer is only applicable if you are incorporated in a foreign jurisdiction. We reissue th e comments.
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 Exchange Act rules require. Since the company and its management are
K.W. Diepholz DynaResource, Inc. November 21 , 2012 Page 2
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statemen t from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to 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 securities laws of the United States.
You may contact John Coleman , Mining Engineer, at ( 202) 551 -3610 with questions about engineering comments. Please contact me at (202) 551 -3795 with any other questions.
Sincerely,
/s/ John Reynolds
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November 2 1, 2012 Via E-mail K.W. Diepholz Chairman and Chief Executive Officer DynaResource, Inc. 222 W. Las Colinas Boulevard Suite 744 East Tower Irving, Texas 75039 Re: DynaResource, Inc. Form 10-K for Fiscal Year Ended December 31, 2011 Filed April 2, 2012 Response dated November 14, 2012 File No. 000-30371 Dear Mr. Diepholz : 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 this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will pr ovide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Form 10 -K for Fiscal Year Ended December 31 General 1. We note your response to comments 1, 2, and 5 from our letter dated October 31, 2012. As a company incorpora ted in Delaware, only proven and probable reserves may be disclosed in filings with the United States Securities and Exchange Commission. The exemption to which you refer is only applicable if you are incorporated in a foreign jurisdiction. We reissue th e comments. 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 Exchange Act rules require. Since the company and its management are K.W. Diepholz DynaResource, Inc. November 21 , 2012 Page 2 in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provide a written statemen t from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to 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 securities laws of the United States. You may contact John Coleman , Mining Engineer, at ( 202) 551 -3610 with questions about engineering comments. Please contact me at (202) 551 -3795 with any other questions. Sincerely, /s/ John Reynolds John Reynolds Assistant Director