SecProbe.io

United States securities and exchange commission logo
April 11, 2023
Michael White
Chief Financial Officer
Piedmont Lithium Inc.
32 North Main Street, Suite 100
Belmont, North Carolina
28012
Re:Piedmont Lithium Inc.
Form 10-KT for the Fiscal Year ended December 31, 2021
Filed February 28, 2022
File No. 001-38427
Dear Michael White:
            We have reviewed your March 17, 2023 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
March 6, 2023 letter.
Form 10-KT for the Fiscal Year ended December 31, 2021
General
1.We understand from your responses to prior comments that you will amend your annual
report for the fiscal year ended December 31, 2022 to address the concerns outlined in
those comments, to include filing an amendment to the more recent amendment to the
technical report summary.  Please also make appropriate changes to disclosures regarding
content of the study that is referenced in the following comment in this letter and file the
amendment in conjunction with your response.
2.We note that your response to prior comment one includes proposed changes regarding
your references to inferred resources in the Ewoyaa Lithium, Ghana, West Africa pre-

 FirstName LastNameMichael White
 Comapany NamePiedmont Lithium Inc.
 April 11, 2023 Page 2
 FirstName LastName
Michael White
Piedmont Lithium Inc.
April 11, 2023
Page 2
feasibility study.  For example, we note that you intend to include a cautionary statement
about the inclusion of inferred mineral resources in the production target, and that upon
completion of a feasibility study in July 2023, you intend to update production targets to
disclose estimates of mineral reserves.

However, while the 2012 Edition of the JORC Code accommodates inclusion of inferred
resources in a scoping study, this does not appear to be the case for either a pre-feasibility
study or a preliminary feasibility study.

Therefore, it appears that you should be either (i) referring to that report as a scoping
study, rather than as a pre-feasibility study, notwithstanding the preparers characterization
of the report; or (ii) excluding the inferred resources and associated economics when
disclosing or referring to content of that report.

If you have an alternative view, please address the following points based on the 2012
Edition of The JORC Code:

•Clause 21 indicates that the confidence associated with estimates of inferred mineral
resources is not sufficient to allow the results of technical and economic parameters
to be used for detailed planning in pre-feasibility or feasibility studies.

•Clause 38 provides for limited cautionary language when inferred resources partially
support a scoping study although does not provide similar accommodations in
relation to a pre-feasibility or feasibility study.
            You may contact John Coleman, Mining Engineer, at (202) 551-3610, or Gus Rodriguez,
Staff Accountant, at (202) 551-3752 if you have questions regarding the comments. You may
contact Karl Hiller, Branch Chief, at (202) 551-3686 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation