Correspondence 0001493152-24-017458 from AMERICAN BATTERY TECHNOLOGY Co (ABAT)
AMERICAN BATTERY TECHNOLOGY Co
Date: May 1, 2024 · CIK: 0001576873 · Accession: 0001493152-24-017458
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-41811
Referenced dates: April 30, 2024
Letter
United States Securities and Exchange Commission Division of Corporation Finance Office of Energy & Transportation Craig Arakawa Re: American Battery Technology Company Form 10-K for the Fiscal Year Ended June 30, 2023 Filed September 28, 2023 File No. 001-41811
Dear Messrs. Coleman and Arakawa:
Set forth below are the responses of American Battery Technology Company (the “Company”) to the comments received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) by letter dated April 30, 2024 regarding the above-referenced Annual Report on Form 10-K (the “Form 10-K”). For your convenience, the Company has set forth below each Staff comment followed by the Company’s response.
Form 10-K for the Fiscal Year Ended June 30, 2023
Item 2. Properties
Tonopah Flats Lithium Exploration Project, page 18
1. We understand that you maintain that your mineral property is not material, however we do not concur with your assessment. Item 1301(c) of Regulation S-K requires all stages of mineral properties, including exploration stage properties, to be considered when assessing mineral property materiality.
Please confirm that you will revise subsequent annual filings to include all of the required disclosures under Item 1304 of Regulation S-K, including the information requested under comments 1 to 3.
If you continue to maintain that your mineral property is not material please provide additional qualitative and/or quantitative information that supports your assertion.
The Company acknowledges the Staff’s comment and will revise subsequent annual filings to include all of the required disclosures under Item 1304 of Regulation S-K, including the information requested under comments 1 to 3, with respect to the Tonopah Flats Lithium Exploration Project.
Location
Mailing Address
Contact
17th Street, Suite 3200
P.O. Box 8749
p: 303.295.8000│f: 303.295.8261
Denver, CO 80202-3921
Denver, CO 80201-8749
www.hollandhart.com
Holland & Hart LLP Anchorage Aspen Billings Boise Boulder Cheyenne Denver Jackson Hole Las Vegas Reno Salt Lake City Santa Fe Washington, D.C.
United States Securities and
Exchange Commission
Page 2
Please contact me ((303) 290-1086) or Bret Meich ((775) 561-0454), the Company’s General Counsel, if you should have any questions regarding the responses contained herein.
Sincerely,
/s/
Amy L. Bowler
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CORRESP
1
filename1.htm
Amy
L. Bowler
Partner
Phone
303.290.1086
abowler@hollandhart.com
May
1, 2024
United
States Securities and Exchange Commission
Division
of Corporation Finance
Office
of Energy & Transportation
100
F Street N.E.
Washington,
DC 20549
Attn:
John Coleman
Craig
Arakawa
Re: American
Battery Technology Company
Form 10-K for the Fiscal Year Ended June 30, 2023
Filed
September 28, 2023
File
No. 001-41811
Dear
Messrs. Coleman and Arakawa:
Set
forth below are the responses of American Battery Technology Company (the “Company”) to the comments received
from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
by letter dated April 30, 2024 regarding the above-referenced Annual Report on Form 10-K (the “Form 10-K”).
For your convenience, the Company has set forth below each Staff comment followed by the Company’s response.
Form
10-K for the Fiscal Year Ended June 30, 2023
Item
2. Properties
Tonopah
Flats Lithium Exploration Project, page 18
1. We
understand that you maintain that your mineral property is not material, however we do not
concur with your assessment. Item 1301(c) of Regulation S-K requires all stages of mineral
properties, including exploration stage properties, to be considered when assessing mineral
property materiality.
Please
confirm that you will revise subsequent annual filings to include all of the required disclosures under Item 1304 of Regulation S-K,
including the information requested under comments 1 to 3.
If
you continue to maintain that your mineral property is not material please provide additional qualitative and/or quantitative information
that supports your assertion.
The
Company acknowledges the Staff’s comment and will revise subsequent annual filings to include all of the required disclosures under
Item 1304 of Regulation S-K, including the information requested under comments 1 to 3, with respect to the Tonopah Flats Lithium Exploration
Project.
Location
Mailing
Address
Contact
555
17th Street, Suite 3200
P.O.
Box 8749
p:
303.295.8000│f: 303.295.8261
Denver,
CO 80202-3921
Denver,
CO 80201-8749
www.hollandhart.com
Holland & Hart LLP Anchorage Aspen Billings
Boise Boulder Cheyenne Denver Jackson Hole Las Vegas Reno Salt Lake City Santa Fe Washington, D.C.
United
States Securities and
Exchange Commission
Page 2
Please
contact me ((303) 290-1086) or Bret Meich ((775) 561-0454), the Company’s General Counsel, if you should have any questions regarding
the responses contained herein.
Sincerely,
/s/
Amy L. Bowler
Amy L. Bowler
Partner
of Holland & Hart llp
ALB:tnt