SEC Comment Letter for DYNARESOURCE, INC. (DYNR) (CIK 0001111741) (DYNR) — Dec 18, 2018
DYNARESOURCE, INC. (DYNR) (CIK 0001111741)
Date: Dec. 18, 2018 · CIK: 0001111741 · Accession: 0000000000-18-038481
AI Filing Summary & Sentiment
File numbers found in text: 000-30371
Letter
December 18, 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 Response dated December 11, 2018 File No. 000-30371 Dear Mr. Diepholz: We have reviewed your December 11, 2018 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our November 28, 2018 letter. 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 have reviewed your response to comment 1 noting you do not believe the costs you capitalized for the medical facility, camp and office infrastructure improvements, tailings pond and liner improvements, new foundation for the Denver Mill, installation cost for Mill #3, other machinery and equipment and transportation equipment relate to mine development. Considering you have not established proven and probable reserves for this mine and you continue to be in the exploration stage, please provide us with a detailed
FirstName LastNameK.W. Diepholz Comapany NameDynaResource, Inc. December 18, 2018 Page 2 FirstName LastName K.W. Diepholz DynaResource, Inc. December 18, 2018 Page 2 discussion of how you determined the probable future economic benefit for each of these capitalized costs. In addition, please provide us with your detailed analysis demonstrating the recoverability of each of these capitalized costs, including: (a) your expected proceeds and associated costs from alternative future uses for each of these capitalized costs and (b) the salvage value for each of these capitalized amounts. Also, tell us the basis for each of your material assumptions, including providing supporting evidence. You may contact Angela Lumley at (202) 551-3398 or Rufus Decker at (202) 551-3769, if you have any questions. Sincerely, Division of Corporation Finance Office of Beverages, Apparel and Mining
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December 18, 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
Response dated December 11, 2018
File No. 000-30371
Dear Mr. Diepholz:
We have reviewed your December 11, 2018 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our
November 28, 2018 letter.
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 have reviewed your response to comment 1 noting you do not believe the costs you
capitalized for the medical facility, camp and office infrastructure improvements, tailings
pond and liner improvements, new foundation for the Denver Mill, installation cost for
Mill #3, other machinery and equipment and transportation equipment relate to mine
development. Considering you have not established proven and probable reserves for this
mine and you continue to be in the exploration stage, please provide us with a detailed
FirstName LastNameK.W. Diepholz
Comapany NameDynaResource, Inc.
December 18, 2018 Page 2
FirstName LastName
K.W. Diepholz
DynaResource, Inc.
December 18, 2018
Page 2
discussion of how you determined the probable future economic benefit for each of these
capitalized costs. In addition, please provide us with your detailed analysis demonstrating
the recoverability of each of these capitalized costs, including: (a) your expected proceeds
and associated costs from alternative future uses for each of these capitalized costs and (b)
the salvage value for each of these capitalized amounts. Also, tell us the basis for each of
your material assumptions, including providing supporting evidence.
You may contact Angela Lumley at (202) 551-3398 or Rufus Decker at (202) 551-3769,
if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Beverages, Apparel and
Mining