SEC Comment Letter for Graphene & Solar Technologies Ltd (GSTX) (CIK 0001497649) (GSTX) — Nov 12, 2019
Graphene & Solar Technologies Ltd (GSTX) (CIK 0001497649)
Date: Nov. 12, 2019 · CIK: 0001497649 · Accession: 0000000000-19-015433
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-174194
Letter
November 12, 2019 Roger May Chief Executive Officer Graphene & Solar Technologies Limited 433 N. Camden Dr., Ste. 600 Beverly Hills, CA 90210 Re:Graphene & Solar Technologies Limited Form 10-K for the fiscal year ended September 30, 2018 Filed January 23, 2019 File No. 333-174194 Dear Mr. May: We have reviewed your October 31, 2019 response to our comment letter 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 these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 18, 2019 letter. Form 10-K for the fiscal year ended September 30, 2018 filed January 23, 2019 Item 2. Properties, page 4 1.We note your response to comments 1 to 3. Please provide your proposed draft disclosure and tell us if these changes will be incorporated in your 10-K for your fiscal year ended September 30, 2019. 2.We note your response to comment 4. Please note that only proven and probable reserves based on a final feasibility study may be disclosed in filings with the United States Securities and Exchange Commission pursuant to the Instructions to Paragraph (b)(5) of Industry Guide 7. It appears the 15 million tons of high purity quartz that are disclosed in your filing are only defined to the inferred resource category. Inferred resources cannot be moved to a proven or probable reserve category without additional geological work. Please revise to remove this tonnage and grade estimate from your filing.
FirstName LastNameRoger May Comapany NameGraphene & Solar Technologies Limited November 12, 2019 Page 2 FirstName LastName Roger May Graphene & Solar Technologies Limited November 12, 2019 Page 2 3.Additionally as a company with no mineral reserves you must be classified as an exploration stage company pursuant to Paragraph (a)(4)(i) of Industry Guide 7. Please revise your filing to clarify that you are an exploration stage company until you have mineral reserves. You may contact John Coleman at 202-551-3610 or Pam Howell at 202-551-3357 if you have questions regarding comments. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: David Fickson
Show Raw Text
November 12, 2019
Roger May
Chief Executive Officer
Graphene & Solar Technologies Limited
433 N. Camden Dr., Ste. 600
Beverly Hills, CA 90210
Re:Graphene & Solar Technologies Limited
Form 10-K for the fiscal year ended September 30, 2018
Filed January 23, 2019
File No. 333-174194
Dear Mr. May:
We have reviewed your October 31, 2019 response to our comment letter 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
September 18, 2019 letter.
Form 10-K for the fiscal year ended September 30, 2018 filed January 23, 2019
Item 2. Properties, page 4
1.We note your response to comments 1 to 3. Please provide your proposed draft disclosure
and tell us if these changes will be incorporated in your 10-K for your fiscal year ended
September 30, 2019.
2.We note your response to comment 4. Please note that only proven and probable reserves
based on a final feasibility study may be disclosed in filings with the United States
Securities and Exchange Commission pursuant to the Instructions to Paragraph (b)(5) of
Industry Guide 7. It appears the 15 million tons of high purity quartz that are disclosed in
your filing are only defined to the inferred resource category. Inferred resources cannot
be moved to a proven or probable reserve category without additional geological work.
Please revise to remove this tonnage and grade estimate from your filing.
FirstName LastNameRoger May
Comapany NameGraphene & Solar Technologies Limited
November 12, 2019 Page 2
FirstName LastName
Roger May
Graphene & Solar Technologies Limited
November 12, 2019
Page 2
3.Additionally as a company with no mineral reserves you must be classified as an
exploration stage company pursuant to Paragraph (a)(4)(i) of Industry Guide 7. Please
revise your filing to clarify that you are an exploration stage company until you have
mineral reserves.
You may contact John Coleman at 202-551-3610 or Pam Howell at 202-551-3357 if you
have questions regarding comments.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: David Fickson