Correspondence 0001493152-25-004318 from Idaho Copper Corp (COPR)
Idaho Copper Corp
Date: Jan. 30, 2025 · CIK: 0001263364 · Accession: 0001493152-25-004318
AI Filing Summary & Sentiment
File numbers found in text: 333-108715, 333-280762
Referenced dates: January 3, 2025, October 23, 2024
Letter
Securities and Exchange Commission Division of Corporation Finance Office of Industrial Applications and Services Form 10-K for the Fiscal Year Ended January 31, 2024 Filed May 15, 2024 Form 8-K Filed October 8, 2024 File No. 333-108715
Dear Sir and Madam:
On behalf of Idaho Copper Corporation, a Nevada corporation (the “Company”), we hereby file with the Securities and Exchange Commission (the “Commission”) this correspondence in response to the comments of the staff (the “Staff”), dated January 3, 2025, with reference to the Company’s Form 10-K filed with the Commission on May 15, 2024.
For the convenience of the Staff, each of the Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.
Form 10-K for the Fiscal Year Ended January 31, 2024
Item 2. Properties, page 7
1. Consistent with the comment in our letter dated October 23, 2024, if you continue to claim mineral resources please file an amended Form 10-K for the Fiscal Year Ended January 30, 2024 with the mineral resource disclosure, as required by Item 1304(d) of Regulation S-K. The resource disclosure should include the price, cut-off grade, metallurgical recovery factor, and the specific point of reference in which the resources were calculated, such as in-situ, mill feed, saleable product, etc. Additionally, also consistent with our comment letter dated October 23, 2024, include the incremental mineral property disclosure in your amended filing, as required by item 1304(b) of Regulation S-K, including:
● the location of your property, accurate to within one mile, using an easily recognizable coordinate system,
● the total cost or book value of the property, and
● a brief description of any significant encumbrances to the property, including current and future permitting requirements and the associated timelines and conditions.
Response: The Company intends to amend its form 10-K for the Fiscal Year Ended January 31, 2024 once it clears comments with the Commission for its Registration Statement filed on Form S-1 (File No. 333-280762) such that all disclosure will align in accordance with the Comments of the Staff.
420 Lexington Avenue, Suite 2446, New York, NY 10170 | 646-861-7891
12121 Wilshire Blvd., Suite 810, Los Angeles, CA 90025 | 818-930-5686
If we can provide any further assistance, please do not hesitate to contact the undersigned.
Sincerely,
THE
CRONE LAW GROUP P.C.
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CORRESP
1
filename1.htm
Mark
E. Crone
Managing
Partner
mcrone@cronelawgroup.com
January
30, 2025
Securities
and Exchange Commission
Division
of Corporation Finance
Office
of Industrial Applications and Services
100
F Street, N.E.
Washington,
DC 20549
Attn:
Steve Lo
Kimberly
Calder
John
Coleman
Cheryl
Brown
Irene
Barberena-Meissner
Re:
Idaho
Copper Corporation
Form
10-K for the Fiscal Year Ended January 31, 2024
Filed
May 15, 2024
Form
8-K Filed October 8, 2024
File
No. 333-108715
Dear
Sir and Madam:
On
behalf of Idaho Copper Corporation, a Nevada corporation (the “Company”), we hereby file with the Securities and Exchange
Commission (the “Commission”) this correspondence in response to the comments of the staff (the “Staff”), dated
January 3, 2025, with reference to the Company’s Form 10-K filed with the Commission on May 15, 2024.
For
the convenience of the Staff, each of the Staff’s comments is included and is followed by the corresponding response of the Company.
Unless the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to
the Company on a consolidated basis.
Form
10-K for the Fiscal Year Ended January 31, 2024
Item
2. Properties, page 7
1.
Consistent
with the comment in our letter dated October 23, 2024, if you continue to claim mineral resources please file an amended Form 10-K
for the Fiscal Year Ended January 30, 2024 with the mineral resource disclosure, as required by Item 1304(d) of Regulation S-K. The
resource disclosure should include the price, cut-off grade, metallurgical recovery factor, and the specific point of reference in
which the resources were calculated, such as in-situ, mill feed, saleable product, etc. Additionally, also consistent with our comment
letter dated October 23, 2024, include the incremental mineral property disclosure in your amended filing, as required by item 1304(b)
of Regulation S-K, including:
●
the location of your property, accurate to within one mile, using an easily recognizable coordinate system,
●
the total cost or book value of the property, and
● a
brief description of any significant encumbrances to the property, including current and future permitting requirements and the
associated timelines and conditions.
Response:
The Company intends to amend its form 10-K for the Fiscal Year Ended January 31, 2024 once it clears comments with the Commission
for its Registration Statement filed on Form S-1 (File No. 333-280762) such that all disclosure will align in accordance with the Comments
of the Staff.
420 Lexington Avenue, Suite 2446, New York, NY 10170
| 646-861-7891
12121 Wilshire Blvd., Suite 810, Los Angeles, CA 90025
| 818-930-5686
If
we can provide any further assistance, please do not hesitate to contact the undersigned.
Sincerely,
THE
CRONE LAW GROUP P.C.
cc:
Steven Rudofsky
Chief
Executive Officer
420 Lexington Avenue, Suite 2446, New York, NY 10170
| 646-861-7891
12121 Wilshire Blvd., Suite 810, Los Angeles, CA 90025
| 818-930-5686