SEC Company Response from JED OIL INC. (CIK 0001258021) — Nov 3, 2005
JED OIL INC. (CIK 0001258021)
Date: Nov. 3, 2005 · CIK: 0001258021 · Accession: 0000912282-05-000821
AI Filing Summary & Sentiment
File numbers found in text: 333-128711
Referenced dates: October 13, 2005
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CORRESP
1
filename1.htm
November 2, 2005
Tangela Richter
Division of Corporate Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0405
Re:
Responses
to the Securities and Exchange Commission
Staff Comments dated October 13, 2005, regarding JED Oil Inc.
Form F-3 filed September 30, 2005
File No. 333-128711
Dear Ms. Richter:
This letter responds to the
staff’s comments set forth in the October 13, 2005 letter regarding the
above-referenced Form F-3. For your convenience, the staff’s comments are included
below and we have numbered our responses accordingly.
In some of the responses, we have
agreed to change or supplement the disclosures in future filings. We are doing so in the
spirit of cooperation with the staff of the Securities and Exchange Commission, and not
because we believe our prior filing is materially deficient or inaccurate. Accordingly,
any changes implemented in future filings should not be taken as an admission that prior
disclosures were in any way deficient.
Our responses are as follows:
Selling Shareholder, page
15
Staff Comment No. 1.
Expand
the table to include the natural person with power to vote or to dispose of the securities
offered for resale by the entity listed as selling shareholder. If more than one holder is
listed as a beneficial owner for the same securities, include explanatory text or
footnotes. See Interpretation 4S of the Regulation S-K portion of the March 1999
supplement to the CF telephone interpretation manual.
JED’s Response:
The
table has been expanded to include the requested information.
November 2, 2005
Page 2
Plan of Distribution,
page 15
Staff Comment No. 2.
We
note that the selling shareholder may engage in short sales of your common stock. Please
see Corporation Finance Telephone Interpretation A.65 in that regard.
JED’s Response:
The
reference to “through short sales of shares” in the Plan of Distribution has
been clarified to read “to cover short sales and other hedging transactions made
after the date that the registration statement of which this prospectus is a part is
declared effective by the Securities and Exchange Commission (“SEC”)", in
accordance with the requirements of Interpretation A.65.
Thank you for your review of the
revised filing. If you should have any questions regarding the annual report or our
response letter, please do not hesitate to contact me at (403) 537-3250 or Kimberley
Anderson at Dorsey & Whitney LLP at (206) 903-8803.
Sincerely,
JED Oil Inc.
Bruce Stewart
Chief Financial Officer
cc:
Thomas J. Jacobsen
Chief Executive Officer
Marcia Johnston
General Counsel