SEC Comment Letter 0000000000-23-009236 to INTERNATIONAL TOWER HILL MINES LTD (THM) (CIK 0001134115) (THM)
INTERNATIONAL TOWER HILL MINES LTD (THM) (CIK 0001134115)
Date: Aug. 23, 2023 · CIK: 0001134115 · Accession: 0000000000-23-009236
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File numbers found in text: 333-273881
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United States securities and exchange commission logo
August 22, 2023
Karl L. Hanneman
Chief Executive Officer
International Tower Hill Mines Ltd.
506 Gaffney Road, Suite 200
Fairbanks, AK 99701
Re:International Tower Hill Mines Ltd.
Registration Statement on Form S-3
Filed August 10, 2023
File No. 333-273881
Dear Karl L. Hanneman:
We have limited our review of your registration statement to those issues we have
addressed in our 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 by amending your registration statement and providing the
requested information. 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 registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-3 filed August 10, 2023
General
1.Please note that the staff’s comments with regard to your Form 10-K for the fiscal year
ended December 31, 2022 will need to be resolved before we will be in a position to
declare your registration statement effective. Please also confirm that you will amend the
registration statement, as appropriate, to reflect your responses to our comments on the
Form 10-K, as applicable.
FirstName LastNameKarl L. Hanneman
Comapany NameInternational Tower Hill Mines Ltd.
August 22, 2023 Page 2
FirstName LastName
Karl L. Hanneman
International Tower Hill Mines Ltd.
August 22, 2023
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Liz Packebusch, Staff Attorney, at (202) 551-8749 or Daniel Morris, Legal
Branch Chief, at (202) 551-3314 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: David Crandall