SEC Comment Letter for PEDEVCO CORP (PED) (CIK 0001141197) (PED) — Jan 18, 2013
PEDEVCO CORP (PED) (CIK 0001141197)
Date: Jan. 18, 2013 · CIK: 0001141197 · Accession: 0000000000-13-003366
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-53725
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE January 18, 2013 Via E -Mail Michael L. Peterson Executive Vice President and Chief Financial Officer PEDEVCO Corp . 4125 Blackhawk Plaza Circle, Suite 201 Danville, California 94506
Re: PEDEVCO CORP . Form 8-K Filed January 15, 2013 File No. 000-53725
Dear M r. Peterson :
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 this letter within five business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. 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 filing and the information you provide in response to these comments, we may have additional comments.
Form 8 -K Filed January 15, 2013
1. We note you have filed a Form 8 -K with reference to Item 4.01 , Changes in Registrant’s Certifying Accountant . However, as the content of the filing pertains to Item 4.02 , Non- Reliance on Previously Issued Financial Statements , please contact Filer Technical Support at (202) 551 -8900 to have the Item reference revised .
Closing Comments
We urge all persons who are responsible for the accuracy and adequ acy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Michael L. Peterson PEDEVCO C orp. January 18, 2013 Page 2
In responding to our comments, please provide a written statement from the company acknowledging that :
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact Jennifer O’Brien at (202) 551 -3721 if you have questions regarding comments on the financial statements and re lated matters. Please contact me at (202) 551 -3311 with any other questions.
Sincerely,
/s/ Ethan Horowitz
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
January 18, 2013
Via E -Mail
Michael L. Peterson
Executive Vice President and Chief Financial Officer
PEDEVCO Corp .
4125 Blackhawk Plaza Circle, Suite 201
Danville, California 94506
Re: PEDEVCO CORP .
Form 8-K
Filed January 15, 2013
File No. 000-53725
Dear M r. Peterson :
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 this letter within five business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response. 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 filing and the information you provide in
response to these comments, we may have additional comments.
Form 8 -K Filed January 15, 2013
1. We note you have filed a Form 8 -K with reference to Item 4.01 , Changes in Registrant’s
Certifying Accountant . However, as the content of the filing pertains to Item 4.02 , Non-
Reliance on Previously Issued Financial Statements , please contact Filer Technical
Support at (202) 551 -8900 to have the Item reference revised .
Closing Comments
We urge all persons who are responsible for the accuracy and adequ acy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require. Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Michael L. Peterson
PEDEVCO C orp.
January 18, 2013
Page 2
In responding to our comments, please provide a written statement from the company
acknowledging that :
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.
You may contact Jennifer O’Brien at (202) 551 -3721 if you have questions regarding
comments on the financial statements and re lated matters. Please contact me at (202) 551 -3311
with any other questions.
Sincerely,
/s/ Ethan Horowitz
Ethan Horowitz
Branch Chief