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SEC Comment Letter for UR-ENERGY INC (URG) (CIK 0001375205) (URG) — Nov 26, 2010

UR-ENERGY INC (URG) (CIK 0001375205)
Date: Nov. 26, 2010 · CIK: 0001375205 · Accession: 0000000000-10-070821

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Referenced dates: August 20, 2010, November 4, 2010

Date
November 26, 2010
Author
H. Roger Schwall
Form
UPLOAD
Company
UR-ENERGY INC (URG) (CIK 0001375205)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 -4628 DIVISION OF CORPORATION FINANCE MAIL STOP 4628 November 26, 2010 Mr. Roger Smith Chief Financial Officer Ur-Energy Incorporated 10758 W. Centennial R oad, Suite 200 Littleton , Colorado 80127

Re: Ur-Energy Incorporated Form 20-F for the Fiscal Year Ended December 31, 2009 Filed March 12 , 2010 Response letter dated August 20, 2010 Response letter dated November 4, 2010 File No. 1-33905

Dear Mr. Smith :

We have reviewed your response letter dated November 4 , 2010 and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested res ponse. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in response t o these comments, we may have additional comments.

Mr. Roger Smith Ur-Energy Incorporated November 26 , 2010 Page 2

Form 20-F for Fiscal Year Ending December 31, 2009 filed March 12, 2010

Engineering Comments

1. We note your response to our previous comment number 1, stating you propose to revise your disclosure on a prospective basis. We believe you should proceed with filing an amendment to your Form 20 -F, incorporating appropriate revisions responding to all comments raised.

2. We note your response to our previous comment number 2. In addition we note you sta te you will disclose the quantity and grade where contained pounds are referenced. Additionally, p lease disclose the tons and grade associated with your 24 to 28 million pound exploration target.

3. We note your response to our previous comment number 3, stating Lyntek can only use an indicated mineral resource because there is insufficient delineation of the project for economic consideration. Please revise your disclos ure on page 14 of your 20 -F which states the preliminary assessment report can only u se mineral indicated resources which are considered too speculative geologically to have economic considerations applied to them. In addition, please revise your technical report which contains similar language.

Closing Comments

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management ar e 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 responding to our comments, please provide a written statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the disclosure in the filing;

staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

Mr. Roger Smith Ur-Energy Incorporated November 26 , 2010 Page 3

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.

You may contact John Coleman at (202) 551-3610 with questions about engineering commen ts. Please contact me at (202) 551 -3740 with any other questions.

Sincerely,
H. Roger Schwall
Assistant Director

Show Raw Text
UNITED  STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4628

DIVISION OF
CORPORATION FINANCE
MAIL STOP 4628
         November  26, 2010

Mr. Roger Smith
Chief Financial Officer
Ur-Energy Incorporated
10758 W. Centennial R oad, Suite 200
Littleton , Colorado  80127

 Re: Ur-Energy Incorporated
  Form 20-F for the Fiscal Year Ended  December 31, 2009
Filed  March 12 , 2010
Response letter dated August 20, 2010
Response letter dated November 4, 2010
File No.  1-33905

Dear Mr. Smith :

We have reviewed your response letter dated November 4 , 2010  and have the
following comments. In some of our comments, we may ask you  to provide us with
information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the
requested res ponse. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your filing and the information you provide in
response t o these comments, we may have additional comments.

Mr. Roger Smith
Ur-Energy Incorporated
November 26 , 2010
Page 2

Form 20-F for Fiscal  Year Ending December 31,  2009 filed March 12, 2010

Engineering Comments

1. We note your response to our previous comment number 1, stating you propose to
revise your disclosure  on a prospective basis.  We believe you should proceed
with filing an amendment to your Form 20 -F, incorporating appropriate revisions
responding to all comments raised.

2. We note your response to our previous comment number 2.  In addition we note
you sta te you will disclose the quantity and grade where contained pounds are
referenced.  Additionally, p lease disclose the tons and grade associated with your
24 to 28 million pound exploration target.

3. We note your response to our previous comment number 3,  stating Lyntek can
only use an indicated mineral resource because there is insufficient delineation of
the project for economic consideration.  Please revise your disclos ure on page 14
of your 20 -F which states the preliminary assessment report can only u se mineral
indicated resources which are considered too speculative geologically to have
economic considerations applied to them.  In addition, please revise your technical
report which contains similar language.

Closing Comments

 We urge all persons who  are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company
and its management ar e 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 responding to our comments, please provide a written statement from the
company acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the
filing;

 staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

Mr. Roger Smith
Ur-Energy Incorporated
November 26 , 2010
Page 3

 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.

You may contact John Coleman  at (202) 551-3610  with questions about
engineering commen ts.  Please contact me at (202) 551 -3740  with any other questions.

        Sincerely,

H. Roger Schwall
Assistant Director