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Correspondence 0001493152-25-007002 from Idaho Copper Corp (COPR)

Idaho Copper Corp
Date: Feb. 14, 2025 · CIK: 0001263364 · Accession: 0001493152-25-007002

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File numbers found in text: 333-280762

Referenced dates: February 5, 2025

Date
Feb. 14, 2025
Author
THE
Form
CORRESP
Company
Idaho Copper Corp

Letter

Securities and Exchange Commission Division of Corporation Finance Office of Industrial Applications and Services Re: Idaho Copper Corporation Amendment No. 4 to Registration Statement on Form S-1 Submitted January 24, 2025 File No. 333-280762

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”) an amended registration statement on Form S-1 (the “Amended Registration Statement”) in response to the comments of the staff (the “Staff”), dated February 5, 2025, with reference to the Company’s Registration Statement on Form S-1/A filed with the Commission on January 24, 2025.

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.

Amendment No. 4 to Registration Statement on Form S-1

Management’s Discussion and Analysis of Financial Condition and Results of Operations Liquidity and Capital Resources, page 25

1. We note you disclose that you “do not have sufficient resources to effectuate your business” and “expect to incur expenses offset by revenues during the next twelve months of operations.” You also state that “the Company does not project revenue for the next few years.” Please expand on the revenues you expect to offset expenses during the next twelve months of operations, given that you historically have had no revenue or revise the contradicting statements accordingly. We note that we have previously issued this comment.

Response: The Amended Registration Statement has been revised in accordance with the comments of the Staff on page 25.

We hope the Amended Registration Statement addresses the comments of the Commission. If we can provide any further assistance, please do not hesitate to contact the undersigned.

Sincerely,
THE
CRONE LAW GROUP P.C.

Show Raw Text
CORRESP
1
filename1.htm

    Mark
                                            E. Crone

    Managing
    Partner

    mcrone@cronelawgroup.com

February
14, 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

    Amendment
    No. 4 to Registration Statement on Form S-1

    Submitted
    January 24, 2025

    File
    No. 333-280762

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”) an amended registration statement on Form S-1 (the “Amended Registration Statement”)
in response to the comments of the staff (the “Staff”), dated February 5, 2025, with reference to the Company’s Registration
Statement on Form S-1/A filed with the Commission on January 24, 2025.

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.

Amendment
No. 4 to Registration Statement on Form S-1

Management’s
Discussion and Analysis of Financial Condition and Results of Operations Liquidity and Capital Resources, page 25

    1.
    We
    note you disclose that you “do not have sufficient resources to effectuate your business” and “expect to incur
    expenses offset by revenues during the next twelve months of operations.” You also state that “the Company does not project
    revenue for the next few years.” Please expand on the revenues you expect to offset expenses during the next twelve months
    of operations, given that you historically have had no revenue or revise the contradicting statements accordingly. We note that we
    have previously issued this comment.

Response:
The Amended Registration Statement has been revised in accordance with the comments of the Staff on page 25.

We
hope the Amended Registration Statement addresses the comments of the Commission. 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