SEC Comment Letter 0000000000-25-010731 to Osisko Gold Group Inc. (ODV)
Osisko Gold Group Inc.
Date: Sept. 30, 2025 · CIK: 0001431852 · Accession: 0000000000-25-010731
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File numbers found in text: 333-290216
Letter
September 30, 2025 Sean Roosen Chief Executive Officer Osisko Development Corp. 1100 Avenue des Canadiens-de-Montréal Suite 300 Montréal, Québec H3B 2S2 Canada Re:Osisko Development Corp. Registration Statement on Form F-3 Filed September 12, 2025 File No. 333-290216 Dear Sean Roosen: We have conducted a limited review of your registration statement and have the following comments. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies 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 registration statement and the information you provide in response to this letter, we may have additional comments. Registration Statement on Form F-3 General We note you have incorporated by reference your Annual Report on Form 40-F for fiscal year ended December 31, 2024, as well as your NI 43-101 Technical Report, Feasibility Study for the Cariboo Gold Project on Form 6-K, which does not provide the mining disclosure requirements of subpart 1300 of Regulation S-K and the technical report summary requirements in Item 601(b)(96). See for example the technical report summary required under Item 1302(b)(2) of Regulation S-K. Section II.H.1.i. of the Final Rule “Modernization of Property Disclosures for Mining Registrants” (October 31, 2018) provides "the sole group of Canadian registrants that 1.
September 30, 2025 Page 2 could continue to report pursuant to Canadian disclosure requirements following adoption of the revised mining disclosure rules would be those Canadian issuers that report pursuant to the Multijurisdictional Disclosure System (‘MJDS’)."
Please provide us with your analysis supporting your determination that you are currently eligible to file under the MJDS. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Michael Purcell at 202-551-5351 or Irene Barberena-Meissner at 202- 551-6548 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc:Thomas Rose
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September 30, 2025
Sean Roosen
Chief Executive Officer
Osisko Development Corp.
1100 Avenue des Canadiens-de-Montréal
Suite 300
Montréal, Québec
H3B 2S2
Canada
Re:Osisko Development Corp.
Registration Statement on Form F-3
Filed September 12, 2025
File No. 333-290216
Dear Sean Roosen:
We have conducted a limited review of your registration statement and have the
following comments.
Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies 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 registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement on Form F-3
General
We note you have incorporated by reference your Annual Report on Form 40-F for
fiscal year ended December 31, 2024, as well as your NI 43-101 Technical Report,
Feasibility Study for the Cariboo Gold Project on Form 6-K, which does not provide
the mining disclosure requirements of subpart 1300 of Regulation S-K and the
technical report summary requirements in Item 601(b)(96). See for example the
technical report summary required under Item 1302(b)(2) of Regulation S-K. Section
II.H.1.i. of the Final Rule “Modernization of Property Disclosures for Mining
Registrants” (October 31, 2018) provides "the sole group of Canadian registrants that 1.
September 30, 2025
Page 2
could continue to report pursuant to Canadian disclosure requirements following
adoption of the revised mining disclosure rules would be those Canadian issuers that
report pursuant to the Multijurisdictional Disclosure System (‘MJDS’)."
Please provide us with your analysis supporting your determination that you are
currently eligible to file under the MJDS.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Michael Purcell at 202-551-5351 or Irene Barberena-Meissner at 202-
551-6548 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Thomas Rose