SEC Comment Letter 0000000000-23-000020 to EESTech, Inc. (EESH) (CIK 0001138867) (EESH)
EESTech, Inc. (EESH) (CIK 0001138867)
Date: Jan. 3, 2023 · CIK: 0001138867 · Accession: 0000000000-23-000020
AI Filing Summary & Sentiment
File numbers found in text: 000-32863
Referenced dates: November 22, 2022
Letter
United States securities and exchange commission logo January 3, 2023 Murray Bailey Chief Executive Officer and President EESTech, Inc. Suite 417, 241 Adelaide Street Brisbane, 4000, Australia Re:EESTech, Inc. Registration Statement on Form 10-12G Filed December 16, 2022 File No. 000-32863 Dear Murray Bailey: We have reviewed your filing and have the following 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 these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response and any amendment you may file in response to these comments, we may have additional comments. Any reference to prior comments is to our prior comment letter dated November 22, 2022. Registration Statement on Form 10-12G filed December 16, 2022 Description of Business Samancor Chrome Holdings Proprietary Limited, page 11 1.We note your response to prior comment 5, disclosing an estimated investment of US$50 million for the commissioning of the Samancor FeCr slag reclamation facility, which is anticipated to generate approximately US$90 million per annum with an EBITDA of approximately 60%, and that project cost includes finished product packaging sold at the gate of the project site. To balance your disclosure, please expand your discussion to describe the nature and estimated amounts of all costs associated with the Samancor contract, including costs to produce and deliver the volumes underlying your $900 million sales value estimate. Additionally, reconcile your cost estimates to your 60% EBITDA.
FirstName LastNameMurray Bailey Comapany NameEESTech, Inc. January 3, 2023 Page 2 FirstName LastName Murray Bailey EESTech, Inc. January 3, 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. You may contact Lily Dang, Staff Accountant, at (202) 551-3867 or Jenifer Gallagher, Staff Accountant, at (202) 551-3706 if you have questions regarding comments on the financial statements and related matters. Please contact Claudia Rios, Staff Attorney, at (202) 551-8770 or Karina Dorin, Staff Attorney, at (202) 551-3763 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: David Mittelman
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United States securities and exchange commission logo
January 3, 2023
Murray Bailey
Chief Executive Officer and President
EESTech, Inc.
Suite 417, 241 Adelaide Street
Brisbane, 4000, Australia
Re:EESTech, Inc.
Registration Statement on Form 10-12G
Filed December 16, 2022
File No. 000-32863
Dear Murray Bailey:
We have reviewed your filing and have the following 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments. Any reference to prior comments is to our prior
comment letter dated November 22, 2022.
Registration Statement on Form 10-12G filed December 16, 2022
Description of Business
Samancor Chrome Holdings Proprietary Limited, page 11
1.We note your response to prior comment 5, disclosing an estimated investment of US$50
million for the commissioning of the Samancor FeCr slag reclamation facility, which is
anticipated to generate approximately US$90 million per annum with an EBITDA of
approximately 60%, and that project cost includes finished product packaging sold at the
gate of the project site. To balance your disclosure, please expand your discussion to
describe the nature and estimated amounts of all costs associated with the Samancor
contract, including costs to produce and deliver the volumes underlying your $900 million
sales value estimate. Additionally, reconcile your cost estimates to your 60% EBITDA.
FirstName LastNameMurray Bailey
Comapany NameEESTech, Inc.
January 3, 2023 Page 2
FirstName LastName
Murray Bailey
EESTech, Inc.
January 3, 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.
You may contact Lily Dang, Staff Accountant, at (202) 551-3867 or Jenifer Gallagher,
Staff Accountant, at (202) 551-3706 if you have questions regarding comments on the financial
statements and related matters. Please contact Claudia Rios, Staff Attorney, at (202) 551-8770
or Karina Dorin, Staff Attorney, at (202) 551-3763 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: David Mittelman