SEC Comment Letter for MARA Holdings, (MARA) — Feb 4, 2013
MARA Holdings, Inc.
Date: Feb. 4, 2013 · CIK: 0001507605 · Accession: 0000000000-13-006291
AI Filing Summary & Sentiment
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE February 4 , 2013 Via E-mail Mr. Douglas Croxall Chief Executive Officer and Chairman American Strategic Minerals Corporation 2331 Mill Road, Suite 100 Alexandria, VA 22314
Re: American Strategic Minerals Corporation Amendment 2 to Current Report on Form 8 -K Filed January 24 , 201 3 File No. 0-54652
Dear Mr. Croxall :
We have reviewed yo ur filing and have the comment below .
Please respond to this letter within 10 business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response.
Completion of Acquisition or Disposition of Assets, page 1
1. Refer to comment 2 in our January 16, 2013 letter. As requested previously, please disclose clearly whether before the transaction with Sampo the registrant ever generated revenues from operations or engaged in business operations beyond the development or exploratory stage. Further, provide details of t hose activities.
Closing
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. 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 a dequacy of the disclosures that they have made.
In responding to our comments, please provide a written statement from the company acknowledging that:
Mr. Douglas Croxall American Strategic Minerals Corporation February 4 , 2013 Page 2
The company is responsible for the adequacy and accuracy of the disclosure in the filing s.
Staff comme nts or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing s.
The company may not assert staff comments as a defense in any proceeding initiated by the Commission or any pers on under the federal securities laws of the United States.
You may direct questions on comments and disclosure issues to Edward M. Kelly at 202- 551-3728 or Craig E. Slivka at (202) 551 -3729.
Very truly yours ,
/s/ Craig E. Slivka, for
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
February 4 , 2013
Via E-mail
Mr. Douglas Croxall
Chief Executive Officer and Chairman
American Strategic Minerals Corporation
2331 Mill Road, Suite 100
Alexandria, VA 22314
Re: American Strategic Minerals Corporation
Amendment 2 to Current Report on Form 8 -K
Filed January 24 , 201 3
File No. 0-54652
Dear Mr. Croxall :
We have reviewed yo ur filing and have the comment below .
Please respond to this letter within 10 business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.
Completion of Acquisition or Disposition of Assets, page 1
1. Refer to comment 2 in our January 16, 2013 letter. As requested previously, please disclose
clearly whether before the transaction with Sampo the registrant ever generated revenues
from operations or engaged in business operations beyond the development or exploratory
stage. Further, provide details of t hose activities.
Closing
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in
the filing s to be certain that the filing s include the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require. 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 a dequacy of the disclosures that they have made.
In responding to our comments, please provide a written statement from the company
acknowledging that:
Mr. Douglas Croxall
American Strategic Minerals Corporation
February 4 , 2013
Page 2
The company is responsible for the adequacy and accuracy of the disclosure in the
filing s.
Staff comme nts or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing s.
The company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any pers on under the federal securities laws of the United
States.
You may direct questions on comments and disclosure issues to Edward M. Kelly at 202-
551-3728 or Craig E. Slivka at (202) 551 -3729.
Very truly yours ,
/s/ Craig E. Slivka, for
Pamela A. Long
Assistant Director
cc: Via E-mail
Harvey J. Kesner, Esq.
Sichenzia Ross Friedman Ference LLP
61 Broadway, 32nd Floor
New York, NY 10006