SEC Comment Letter for MARA Holdings, (MARA) — Mar 29, 2012
MARA Holdings, Inc.
Date: March 29, 2012 · CIK: 0001507605 · Accession: 0000000000-12-016137
AI Filing Summary & Sentiment
File numbers found in text: 333-171214
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE March 27, 2012 Via U.S. Mail Mr. George Glasier President and Chief Executive Officer American Strategic Minerals Corporation 31161 Highway 90 Nucla, CO 81424
Re: American Strategic Minerals Corporation Amended Current Report on Form 8-K Filed January 14, 2012 File No. 333-171214
Dear Mr. Glasier: We reviewed the filing and have the comments below. 1. We note your response to comment 6 of our le tter dated February 27, 2012. You state in your response letter that the Centennial-S un Cup property was subject to extractive operations and generated revenues; however, on page 10 of the amended Form 8-K you state that the “Centennial-Sun Cup property was subj ect to extractive operativ es and has generated revenue in the past,” and on page 11 you stat e just the opposite. Please reconcile this disclosure. Further, please provide a more specific time refe rence when referring to “past” activities and revenues. 2. Please file the agreement with GRQ Consultants as an exhibit. Closing
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filings to be certain that the filings include the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. 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 that they have made. In responding to our comments, please provi de a written statement from the company acknowledging that:
Mr. George Glasier American Strategic Minerals Corporation March 27, 2012 Page 2 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 do not foreclose the Commission from taking a ny action with respect to the filings.
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 direct questions on comments and disc losure issues to Edward M. Kelly at 202- 551-3728 or Craig E. Slivka at (202) 551-3729 if you have any questions on the comments.
Very truly yours,
/ s / C r a i g E . S l i v k a , f o r
Pamela A. Long Assistant Director
cc: Via Facsimile
Harvey J. Kesner, Esq. Sichenzia Ross Friedman Ference LLP 61 Broadway, 32nd Floor New York, NY 10006
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
March 27, 2012
Via U.S. Mail
Mr. George Glasier President and Chief Executive Officer American Strategic Minerals Corporation 31161 Highway 90
Nucla, CO 81424
Re: American Strategic Minerals Corporation
Amended Current Report on Form 8-K Filed January 14, 2012 File No. 333-171214
Dear Mr. Glasier:
We reviewed the filing and have the comments below.
1. We note your response to comment 6 of our le tter dated February 27, 2012. You state in
your response letter that the Centennial-S un Cup property was subject to extractive
operations and generated revenues; however, on page 10 of the amended Form 8-K you state
that the “Centennial-Sun Cup property was subj ect to extractive operativ es and has generated
revenue in the past,” and on page 11 you stat e just the opposite. Please reconcile this
disclosure. Further, please provide a more specific time refe rence when referring to “past”
activities and revenues.
2. Please file the agreement with GRQ Consultants as an exhibit.
Closing
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in
the filings to be certain that the filings include the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. 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 that they have made.
In responding to our comments, please provi de a written statement from the company
acknowledging that:
Mr. George Glasier
American Strategic Minerals Corporation March 27, 2012 Page 2
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 do not
foreclose the Commission from taking a ny action with respect to the filings.
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 direct questions on comments and disc losure issues to Edward M. Kelly at 202-
551-3728 or Craig E. Slivka at (202) 551-3729 if you have any questions on the comments.
Very truly yours,
/ s / C r a i g E . S l i v k a , f o r
Pamela A. Long Assistant Director
cc: Via Facsimile
Harvey J. Kesner, Esq. Sichenzia Ross Friedman Ference LLP 61 Broadway, 32nd Floor New York, NY 10006