SEC Comment Letter 0000000000-23-012546 to INTERNATIONAL TOWER HILL MINES LTD (THM) (CIK 0001134115) (THM)
INTERNATIONAL TOWER HILL MINES LTD (THM) (CIK 0001134115)
Date: Nov. 15, 2023 · CIK: 0001134115 · Accession: 0000000000-23-012546
AI Filing Summary & Sentiment
File numbers found in text: 333-273881
Letter
United States securities and exchange commission logo November 15, 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. Amendment No. 1 to Registration Statement on Form S-3 Filed November 2, 2023 File No. 333-273881 Dear Karl L. Hanneman: We have reviewed your amended registration statement and have the following comment(s). Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Amendment No. 1 to Registration Statement on Form S-3 filed November 2, 2023 About International Tower Hill Mines Ltd, page 1 1.We note your disclosure on page 1 indicating the company has measured and indicated mineral resources of 704.5 million tonnes, which appears to coincide with the quantification of measured and indicated resources - inclusive of reserves, that the qualified person elected to include in the technical report summary (TRS) pursuant to Item 601(b)(96)(iii)(B)(11)(ii), and we see that you have similar disclosure on page 47 of your annual report.
However, notwithstanding inclusion in the TRS, the disclosures of resources that you provide in the registration statement and annual report should be limited to mineral resources - exclusive of reserves, to comply with Item 1303(b)(3)(ii) and Item 1304(d)(2) of Regulation S-K. Please revise your summary disclosures to quantify reserves separately from resources - exclusive of reserves, and to remove disclosures of resources - inclusive of reserves.
FirstName LastNameKarl L. Hanneman Comapany NameInternational Tower Hill Mines Ltd. November 15, 2023 Page 2 FirstName LastName Karl L. Hanneman International Tower Hill Mines Ltd. November 15, 2023 Page 2 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
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United States securities and exchange commission logo
November 15, 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.
Amendment No. 1 to Registration Statement on Form S-3
Filed November 2, 2023
File No. 333-273881
Dear Karl L. Hanneman:
We have reviewed your amended registration statement and have the following
comment(s).
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Amendment No. 1 to Registration Statement on Form S-3 filed November 2, 2023
About International Tower Hill Mines Ltd, page 1
1.We note your disclosure on page 1 indicating the company has measured and indicated
mineral resources of 704.5 million tonnes, which appears to coincide with the
quantification of measured and indicated resources - inclusive of reserves, that the
qualified person elected to include in the technical report summary (TRS) pursuant to Item
601(b)(96)(iii)(B)(11)(ii), and we see that you have similar disclosure on page 47 of your
annual report.
However, notwithstanding inclusion in the TRS, the disclosures of resources that you
provide in the registration statement and annual report should be limited to mineral
resources - exclusive of reserves, to comply with Item 1303(b)(3)(ii) and Item 1304(d)(2)
of Regulation S-K. Please revise your summary disclosures to quantify reserves separately
from resources - exclusive of reserves, and to remove disclosures of resources - inclusive
of reserves.
FirstName LastNameKarl L. Hanneman
Comapany NameInternational Tower Hill Mines Ltd.
November 15, 2023 Page 2
FirstName LastName
Karl L. Hanneman
International Tower Hill Mines Ltd.
November 15, 2023
Page 2
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