SEC Company Response from Graphene & Solar Technologies Ltd (GSTX) (CIK 0001497649) (GSTX) — Nov 7, 2011
Graphene & Solar Technologies Ltd (GSTX) (CIK 0001497649)
Date: Nov. 7, 2011 · CIK: 0001497649 · Accession: 0001004878-11-000391
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-174194
Referenced dates: November 4, 2011
Letter
Re: Vanguard Energy Corporation Registration Statement on Form S-1 Amendment #5 File No. 333-174194
HART & TRINEN, LLP ATTORNEYS AT LAW 1624 Washington Street Denver, CO 80203 William T. Hart, P.C. ________ Email: harttrinen@aol.com Donald T. Trinen Facsimile: (303) 839-5414 (303) 839-0061 --
Will Hart
November 7, 2011
Paul Monsour Securities and Exchange Commission 100 F Street, NE Washington, DC 20549
This office represents Vanguard Energy Corporation (the "Company"). Amendment No. 5 to the Company's registration statement on Form S-1 has been filed with the Commission. This letter provides the Company's responses to the comments received from the staff by letter dated November 4, 2011. The paragraph numbers in this letter correspond with the numbered paragraphs in the staff's comment letter. The number under the "page number" column indicates the page number in the Registration Statement where the response to the comment can be found.
Page Number -----------
1. Comment complied with. 5, 6
2. Comment complied with. 20
3. When the second extension to the Farmout Agreement was signed, the parties handwrote and initialed "November 30, 2011" over the October 15, 2011 date. The parties neglected to change the August 1, 2011 date at the top of the first extension. Nevertheless, the Farmout Agreement has been extended to November 30, 2011.
4. Comment complied with. 28
5. The disclosure regarding Exxon/Mobile's rights to purchase oil has been expanded. 28, 29
The lease subject to the Exxon/Mobile farmout agreement covers lands in the Batson Dome Field. The farmout agreement is a standard form used by Exxon/Mobile. As stated in the second full paragraph on page 29 of the prospectus, the Batson Dome Field produces negligible amounts of gas. You will also note from the reserve report, filed as Exhibit 99, that none of the Company's reserves are attributable to natural gas. It is not expected that any wells drilled <PAGE>
Page Number -----------
in the Batson Dome Field will produce natural gas in sufficient quantities so as to justify the expense of constructing a pipeline/gathering system which would be needed to collect the gas. Since it is extremely remote that any wells drilled pursuant to the Exxon/Mobile farmout agreement will produce gas in commercial quantities, the Company does not believe that disclosure of Exxon/Mobile's right to purchase gas is necessary.
6. Comment complied with. 36
7. Comment complied with. 48, 49
If you should have any questions concerning the foregoing, please do not hesitate to contact the undersigned.
Very Truly Yours,
HART & TRINEN, L.L.P.
Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
HART & TRINEN, LLP
ATTORNEYS AT LAW
1624 Washington Street
Denver, CO 80203
William T. Hart, P.C. ________ Email: harttrinen@aol.com
Donald T. Trinen Facsimile: (303) 839-5414
(303) 839-0061
--
Will Hart
November 7, 2011
Paul Monsour
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Vanguard Energy Corporation
Registration Statement on Form S-1 Amendment #5
File No. 333-174194
This office represents Vanguard Energy Corporation (the "Company").
Amendment No. 5 to the Company's registration statement on Form S-1 has been
filed with the Commission. This letter provides the Company's responses to the
comments received from the staff by letter dated November 4, 2011. The paragraph
numbers in this letter correspond with the numbered paragraphs in the staff's
comment letter. The number under the "page number" column indicates the page
number in the Registration Statement where the response to the comment can be
found.
Page Number
-----------
1. Comment complied with. 5, 6
2. Comment complied with. 20
3. When the second extension to the Farmout Agreement was
signed, the parties handwrote and initialed "November 30,
2011" over the October 15, 2011 date. The parties neglected
to change the August 1, 2011 date at the top of the first
extension. Nevertheless, the Farmout Agreement has been
extended to November 30, 2011.
4. Comment complied with. 28
5. The disclosure regarding Exxon/Mobile's rights to purchase
oil has been expanded. 28, 29
The lease subject to the Exxon/Mobile farmout agreement
covers lands in the Batson Dome Field. The farmout agreement
is a standard form used by Exxon/Mobile. As stated in the
second full paragraph on page 29 of the prospectus, the
Batson Dome Field produces negligible amounts of gas. You
will also note from the reserve report, filed as Exhibit
99, that none of the Company's reserves are attributable to
natural gas. It is not expected that any wells drilled
<PAGE>
Page Number
-----------
in the Batson Dome Field will produce natural gas in
sufficient quantities so as to justify the expense of
constructing a pipeline/gathering system which would be
needed to collect the gas. Since it is extremely remote
that any wells drilled pursuant to the Exxon/Mobile
farmout agreement will produce gas in commercial
quantities, the Company does not believe that disclosure
of Exxon/Mobile's right to purchase gas is necessary.
6. Comment complied with. 36
7. Comment complied with. 48, 49
If you should have any questions concerning the foregoing, please do not
hesitate to contact the undersigned.
Very Truly Yours,
HART & TRINEN, L.L.P.
/s/ William T. Hart
By:
William T. Hart
<PAGE>
</TEXT>
</DOCUMENT>