SEC Comment Letter for General Moly, Inc (CIK 0001275229) — Feb 2, 2005
General Moly, Inc (CIK 0001275229)
Date: Feb. 2, 2005 · CIK: 0001275229 · Accession: 0000000000-05-005370
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<TYPE>LETTER
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<FILENAME>filename1.txt
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February 2, 2005
Via facsimile to 509-838-0457 and U.S. mail
Robert L. Russell, President
Idaho General Mines, Inc.
10 N. Post Street, Suite 610
Spokane, WA 99201
RE: Idaho General Mines, Inc.
Form 8-K Item 4.01 filed January 20, 2005
File No. 0-50539
Dear Mr. Russell:
We have the following comments with regard to the filing
identified
above. We welcome any questions you may have about our comments.
Please
contact us at the telephone numbers listed at the end of this
letter.
1. It appears that the date on which the new auditor was engaged
as
indicated in the first sentence may contain a typographical error.
Please
revise.
2. Revise the last sentence of the first paragraph to clearly
indicate
whether the former auditor resigned, was dismissed or declined to
stand
for re-election. See Item 304(a)(1)(i) of Regulation S-B.
3. Please revise to provide the statement required by Item
304(a)(1)(ii)
of Regulation S-B regarding the nature of the audit reports on the
company`s financial statements during the last two fiscal years.
4. Include a statement addressing the involvement of the board of
directors or audit committee in the decision to change auditors.
See Item
304(a)(1)(iii) of Regulation S-B.
5. Obtain an updated letter from the former accountants addressing
the
revised disclosures to be included at Exhibit 16 in the amendment.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors 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.
In connection with responding to our comments, please
provide, in
writing, a statement from the company acknowledging that
* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in
the filings reviewed by the staff 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.
In addition, please be advised that the Division of
Enforcement has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our
comments on your filing.
Please provide the supplemental information requested above
within 10
business days from the date of this letter. The supplemental
information
should be filed as correspondence on EDGAR. The amendment
requested in
our comments above should be filed as promptly as possible and
should be
reviewed by the former accountants. As noted, update the letter
required
by Exhibit 16 to cover the revised disclosures. Any questions
regarding
the above should be directed to me at (202) 942-2873, or in my
absence, to
Robert Benton at (202) 942-1811.
Sincerely,
Gabrielle Malits
Staff Accountant
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Idaho General Mines, Inc.
February 2, 2005
Page 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405
DIVISION OF
CORPORATION FINANCE
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