SEC Comment Letter for CANPLATS RESOURCES CORP (CIK 0001156297) — Apr 27, 2005
CANPLATS RESOURCES CORP (CIK 0001156297)
Date: April 27, 2005 · CIK: 0001156297 · Accession: 0000000000-05-020644
AI Filing Summary & Sentiment
Referenced dates: April 21, 2005
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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
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April 27, 2005
via facsimile and U.S. mail
Mr. R.E. Gordon Davis
Chief Executive Officer
Canplats Resources Corporation
999 West Hastings Street, Suite 1180
Vancouver, British Columbia, Canada V6C 2W2
Re: Canplats Resources Corporation
Form 20-F, Filed December 16, 2004
File No. 0-31190
Response letter dated April 21, 2005
Dear Mr. Davis:
We have reviewed the above filing and response letter and
have
the following accounting comments. Where indicated, we think you
should revise your document in response to these comments. If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary. Please be as detailed
as
necessary in your explanation. In some of our comments, we may
ask
you to provide us with supplemental information so we may better
understand your disclosure. After reviewing this information, we
may
or may not raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
20-F for the year ended July 31, 2004
Auditors` report, page F-3
1. We note the revised report of your independent accountants
provided in response to prior comment 3. We note that there was a
revision to the opinion paragraph to indicate that the financial
statements are presented in conformity with U.S. generally
accepted
accounting principles. We understand the report of your
independent
accountants included in the Form 20-F filed December 16, 2004
indicates that the financial statements are presented in
accordance
with Canadian generally accepted accounting principles. Please
request that your accountants provide their basis for revising the
opinion paragraph of their report. In this regard, also indicate
if
you intend to revise your financial statements for the material
differences between Canadian and U.S. generally accepted
accounting
principles disclosed in Note 14.
2. We note that an explanatory paragraph was added to your
accountants` revised report, provided in response to prior comment
3,
to indicate that the consolidated financial statements have been
prepared assuming that the Company will continue as a going
concern.
We note further that your filing also includes a comment by your
auditors that "[their] report to the shareholders dated October 4,
2004 is expressed in accordance with Canadian reporting standards,
which does not permit a reference to such an uncertainty in the
auditors` report when the uncertainty is adequately disclosed in
the
financial statements." Please request that your accountants
address
the apparent discrepancy derived by the reference in the
additional
comment to "Canadian reporting standards" now that their revised
opinion indicates that the financial statements have been
presented
in conformity with U.S. generally accepted accounting principles.
Also, request that your accountants consider the need to continue
to
include the additional comment due to their inclusion of the
explanatory paragraph in their revised accountants` report.
Closing Comments
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
amendment to expedite our review. Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested supplemental information. Detailed cover letters
greatly facilitate our review. Please understand that we may have
additional comments after reviewing your amendment and responses
to
our comments.
You may contact Regina Balderas, Staff Accountant, at (202)
942-7768 or, in her absence, Jill Davis, Branch Chief, at (202)
942-
1996 if you have questions regarding comments on the financial
statements and related matters. Direct questions relating to all
other disclosure issues to the undersigned at (202) 942-1870.
Direct
all correspondence to the following ZIP code: 20549-0405.
Sincerely,
H. Roger Schwall
Assistant Director
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Canplats Resources Corporation
April 27, 2005
page 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405
DIVISION OF
CORPORATION FINANCE
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