SEC Comment Letter for DYNARESOURCE, INC. (DYNR) (CIK 0001111741) (DYNR) — Dec 18, 2012
DYNARESOURCE, INC. (DYNR) (CIK 0001111741)
Date: Dec. 18, 2012 · CIK: 0001111741 · Accession: 0000000000-12-068000
AI Filing Summary & Sentiment
File numbers found in text: 000-30371
Referenced dates: November 21, 2012
Letter
December 18, 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 Filed December 4 , 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 , 2011
General
1. We note your response to comment 1 from our letter dated November 21, 2012. Choosing to list a security on a foreign exchange does not pre -empt you from complying with U .S. securit ies regulation. The refore, the exemption regarding mineral estimates in Instruction 3 to section (b)(5) of Industry Guide 7 is for companies whose jurisdiction is outside of the United St ates. This guidance is not new and is applicable to many companies. We reissue the comment.
K.W. Diepholz DynaResource, Inc. December 18, 2012 Page 2
Please note that the public disclosure of information required under Regulation FD may be furnished to the Securities and Exchange Commission on Form 8 -K.
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 compa ny and its management are 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 statement from the co mpany 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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December 18, 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 Filed December 4 , 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 , 2011 General 1. We note your response to comment 1 from our letter dated November 21, 2012. Choosing to list a security on a foreign exchange does not pre -empt you from complying with U .S. securit ies regulation. The refore, the exemption regarding mineral estimates in Instruction 3 to section (b)(5) of Industry Guide 7 is for companies whose jurisdiction is outside of the United St ates. This guidance is not new and is applicable to many companies. We reissue the comment. K.W. Diepholz DynaResource, Inc. December 18, 2012 Page 2 Please note that the public disclosure of information required under Regulation FD may be furnished to the Securities and Exchange Commission on Form 8 -K. 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 compa ny and its management are 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 statement from the co mpany 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