SEC Comment Letter for DYNARESOURCE, INC. (DYNR) (CIK 0001111741) (DYNR) — Nov 28, 2018
DYNARESOURCE, INC. (DYNR) (CIK 0001111741)
Date: Nov. 28, 2018 · CIK: 0001111741 · Accession: 0000000000-18-036540
AI Filing Summary & Sentiment
File numbers found in text: 000-30371
Letter
November 28, 2018 K.W. Diepholz Chairman and Chief Executive Officer DynaResource, Inc. 222 W. Las Colinas Blvd. Suite 1900 North Tower Irving, Texas 75039 Re:DynaResource, Inc. Form 10-K for Fiscal Year Ended December 31, 2017 Filed April 16, 2018 File No. 000-30371 Dear Mr. Diepholz: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2017 Notes to Consolidated Financial Statements Note 1. Nature of Activities and Significant Accounting Policies Property Design, Construction and Development Costs, page 57 1.We note your disclosure that since the company has not established proven and probable reserves, the costs incurred for the properties' design, construction and development are expensed as incurred. This appears to be inconsistent with your disclosure on page 42 which appears to indicate that approximately $1,273,000 of costs for the pilot mill facility were capitalized. In addition, it appears that approximately $935,000 of similar costs were capitalized for nine months ended September 30, 2018. Please tell us your basis for capitalizing these costs considering that none of your properties contain resources that satisfy the definition of proven and probable reserves.
FirstName LastNameK.W. Diepholz Comapany NameDynaResource, Inc. November 28, 2018 Page 2 FirstName LastName K.W. Diepholz DynaResource, Inc. November 28, 2018 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Blaise Rhodes at (202) 551-3774 or Angela Lumley at (202) 551-3398 if you have questions regarding our comment. Sincerely, Division of Corporation Finance Office of Beverages, Apparel and Mining
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November 28, 2018
K.W. Diepholz
Chairman and Chief Executive Officer
DynaResource, Inc.
222 W. Las Colinas Blvd.
Suite 1900 North Tower
Irving, Texas 75039
Re:DynaResource, Inc.
Form 10-K for Fiscal Year Ended December 31, 2017
Filed April 16, 2018
File No. 000-30371
Dear Mr. Diepholz:
We have reviewed your filing and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2017
Notes to Consolidated Financial Statements
Note 1. Nature of Activities and Significant Accounting Policies
Property
Design, Construction and Development Costs, page 57
1.We note your disclosure that since the company has not established proven and probable
reserves, the costs incurred for the properties' design, construction and development are
expensed as incurred. This appears to be inconsistent with your disclosure on page 42
which appears to indicate that approximately $1,273,000 of costs for the pilot mill
facility were capitalized. In addition, it appears that approximately $935,000 of similar
costs were capitalized for nine months ended September 30, 2018. Please tell us your
basis for capitalizing these costs considering that none of your properties contain
resources that satisfy the definition of proven and probable reserves.
FirstName LastNameK.W. Diepholz
Comapany NameDynaResource, Inc.
November 28, 2018 Page 2
FirstName LastName
K.W. Diepholz
DynaResource, Inc.
November 28, 2018
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact Blaise Rhodes at (202) 551-3774 or Angela Lumley at (202) 551-3398
if you have questions regarding our comment.
Sincerely,
Division of Corporation Finance
Office of Beverages, Apparel and
Mining