SEC Comment Letter for LEGEND INTERNATIONAL HOLDINGS INC (CIK 0001132143) — Jul 28, 2005
LEGEND INTERNATIONAL HOLDINGS INC (CIK 0001132143)
Date: July 28, 2005 · CIK: 0001132143 · Accession: 0000000000-05-039011
AI Filing Summary & Sentiment
File numbers found in text: 000-32551
Referenced dates: July 12, 2005
Letter
Mail Stop 4561 VIA U.S. MAIL AND FAX +61 3 8532 2805 Mr. Peter Lee Chief Financial Officer Legend International Holdings, Inc. Level 8, 580 St. Kilda Road, Melbourne Victoria 3004, Australia
Re: Legend International Holdings, Inc. Form 10-KSB for the year ended December 31, 2004 Filed March 31, 2005 File No. 000-32551
Dear Mr. Lee:
We have reviewed your response letter dated July 12, 2005 and have the following additional comments. Feel free to call us at the telephone numbers listed at the end of this letter.
1. We read your response to comment 2. As of the grant date, your stock had been publicly traded for less than a year and the expected life of the stock option granted was five years. Since historical volatility is not available for your common stock over a period that is commensurate wit the expected option life, you should consider the pattern and level of historical volatility of more mature entities during the initial years those entities were publicly traded. We note your discussion of the volatile stock market price of other gold mining exploration companies on page 11. Please tell us how you considered paragraphs 277 and 284-285 of SFAS 123 in estimating your volatility and reconcile your statement on page 11 with your assumptions used to calculate the fair value of your stock option in accordance with SFAS 123.
2. Please provide us with your calculation of your historical volatility for the period November 6, 2003 to November 12, 2004 referred to in your response to comment 2.
* * * *
You may contact Josh Forgione, at (202) 551-3431, or me, at (202) 551-3403, if you have questions. Please respond to the comments included in this letter within 10 business days or tell us when you will provide us with a response. Please file your response on EDGAR.
Sincerely,
Steven Jacobs
Accounting Branch Chief
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<TEXT>
July 28, 2005
Mail Stop 4561
VIA U.S. MAIL AND FAX +61 3 8532 2805
Mr. Peter Lee
Chief Financial Officer
Legend International Holdings, Inc.
Level 8, 580 St. Kilda Road, Melbourne
Victoria 3004, Australia
Re: Legend International Holdings, Inc.
Form 10-KSB for the year ended December 31, 2004
Filed March 31, 2005
File No. 000-32551
Dear Mr. Lee:
We have reviewed your response letter dated July 12, 2005
and
have the following additional comments. Feel free to call us at
the
telephone numbers listed at the end of this letter.
1. We read your response to comment 2. As of the grant date, your
stock had been publicly traded for less than a year and the
expected
life of the stock option granted was five years. Since historical
volatility is not available for your common stock over a period
that
is commensurate wit the expected option life, you should consider
the
pattern and level of historical volatility of more mature entities
during the initial years those entities were publicly traded. We
note your discussion of the volatile stock market price of other
gold
mining exploration companies on page 11. Please tell us how you
considered paragraphs 277 and 284-285 of SFAS 123 in estimating
your
volatility and reconcile your statement on page 11 with your
assumptions used to calculate the fair value of your stock option
in
accordance with SFAS 123.
2. Please provide us with your calculation of your historical
volatility for the period November 6, 2003 to November 12, 2004
referred to in your response to comment 2.
* * * *
You may contact Josh Forgione, at (202) 551-3431, or me, at
(202) 551-3403, if you have questions. Please respond to the
comments
included in this letter within 10 business days or tell us when
you
will provide us with a response. Please file your response on
EDGAR.
Sincerely,
Steven Jacobs
Accounting Branch Chief
??
??
??
??
Mr. Peter Lee
Legend International Holdings, Inc.
July 28, 2005
Page 1
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