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Correspondence 0001140361-23-012384 from Piedmont Lithium Inc. (PLL, PLLTL) (CIK 0001728205)

Piedmont Lithium Inc. (PLL, PLLTL) (CIK 0001728205)
Date: March 17, 2023 · CIK: 0001728205 · Accession: 0001140361-23-012384

AI Filing Summary & Sentiment

File numbers found in text: 001-38427

Referenced dates: March 6, 2023

Date
March 17, 2023
Author
Not clearly detected
Form
CORRESP
Company
Piedmont Lithium Inc. (PLL, PLLTL) (CIK 0001728205)

Letter

VIA EDGAR SUBMISSION Division of Corporation Finance Office of Energy & Transportation Securities and Exchange Commission Piedmont Lithium Inc. Form 10-KT for the Six Months Ended December 31, 2021 Filed February 28, 2022 File No. 001-38427

Dear Mr. Coleman and Mr. Rodriguez,

Please find our response to the comments set forth in a letter dated March 6, 2023 (the “Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to the above-mentioned Transition Report on Form 10-KT for the six months ended December 31, 2021 (the “2021 10-KT”). References to the “Company,” “Piedmont,” “we,” “us” and “our” in this letter refer to Piedmont Lithium Inc., unless otherwise indicated.

Our Technical Report Summary (the “Original TRS”) was originally filed as an exhibit to the 2021 10-KT. On March 1, 2023, we filed an amendment to the Original TRS (as amended, the “Amended TRS”) as an exhibit to our Form 10-K for the year ended December 31, 2022 (our “2022 10-K”). We will file a further revised TRS (the “Revised TRS”), reflecting the comments provided by the Staff in its Letter (other than Comment 1), as an exhibit to an amendment to our Form 10-K for the year ended December 31, 2022.

For your convenience, we have restated below in bold each comment from the Letter and supplied our responses immediately thereafter. Unless otherwise indicated, all references in this letter to “$” are to United States dollars.

Form 10-KT for the Fiscal Year ended December 31, 2021

General

1.

We note that you filed approximately seven current reports on Form 8-K over the past year to alert investors to corporate presentations that you have posted on your website, in which you have reported economic details for several projects. For example, the January 27, 2023 and February 24, 2023 presentations include a summary of economic details, including mineralization, for the Quebec, Ghana, Tennessee Lithium, and Carolina Lithium projects on pages 8 and 7, respectively.

You include a similar summary in each of the presentations posted during this timeframe and have similar, related, or corresponding details on other pages within your presentations. In footnotes on the summary pages, you identify various announcements and technical reports from which you have sourced some of the details.

As we discussed during our phone conference on February 28, 2023, numerous details presented on these pages appear to diverge from disclosure standards that govern reporting in your periodic reports, such as Item 1300 of Regulation S-K, and Rule 12b-20 of Regulation 12B. For example, we note the following apparent inconsistencies with these requirements that you will need to address.

The pre-feasibility project stage associated with the projects does not appear to be consistent with reporting resources rather than reserves for the projects.

The quantifications of resources for one or more projects appear to reflect summations of inferred resources with other classifications of resources or reserves, which is generally and commonly not permissible due to the low level of confidence associated with estimates of inferred resources.

The 119.1 Mt resource associated with Quebec does not reconcile with reserves of 29.2 Mt for NAL and 12.1 Mt for Authier.

The Quebec/Sayona NAL feasibility study dated May 23, 2022, associated with your $571 million NPV detail, uses a concentrate sales price of $1,242 per ton, which appears to be materially inconsistent with the contractual price at which you will purchase output disclosed as ranging from $500 to $900 per ton.

The Quebec/Authier feasibility study dated November 11, 2019, uses a concentrate sales price of $693/ton, which appears to be materially inconsistent with the contractual price at which NAL will purchase output from the project which, according to the NAL pre-feasibility study dated May 23, 2022, is $205/ton.

The resources of 30.1 Mt associated with the Ghana project does not reconcile with reserves of 18.9 Mt in the corresponding pre-feasibility study dated September 22, 2022; while the production schedule associated with the $1.3 billion NPV detail appears to include about 24.5% inferred resources, which would not be permissible in establishing reserve economics due to low levels of confidence.

The Tennessee PEA, associated with your $2.2 billion NPV detail, indicates you would purchase 196,000 tons per year spodumene concentrate (SC6) and produce 30,000 tons of lithium hydroxide per year, although without indicating the sources of SC6 considering your contractual commitments with Tesla and LG.

Tell us whether you concur with each of the observations listed above and if there are any points with which you do not agree, tell us you position and describe your rationale.

Response 1:

We acknowledge the Staff’s comment. We further advise the Staff that we will undertake the actions described below in response, as applicable, to the Staff’s observations, which are restated below in bold.

The pre-feasibility project stage associated with the projects does not appear to be consistent with reporting resources rather than reserves for the projects.

We concur with the Staff’s comment and in our future presentations, we will disclose mineral reserves for these projects to the extent supported by a pre-feasibility or feasibility level of study.

The quantifications of resources for one or more projects appear to reflect summations of inferred resources with other classifications of resources or reserves, which is generally and commonly not permissible due to the low level of confidence associated with estimates of inferred resources.

We concur with the Staff’s comment and in our future presentations, we will separate measured and indicated mineral resources from inferred resources, and will not provide totals of such resources.

The 119.1 Mt resource associated with Quebec does not reconcile with reserves of 29.2 Mt for NAL and 12.1 Mt for Authier.

We concur with the Staff’s comment and in our future presentations, we will show mineral reserves in our project summaries, to the extent declared, and provide a reconciliation of mineral reserves to mineral resources for each project.

The Quebec/Sayona NAL feasibility study dated May 23, 2022, associated with your $571 million NPV detail, uses a concentrate sales price of $1,242 per ton, which appears to be materially inconsistent with the contractual price at which you will purchase output disclosed as ranging from $500 to $900 per ton.

We advise the Staff that the concentrate sales price assumed by Sayona Quebec in its Quebec/Sayona NAL feasibility study represents a blended average of concentrate sales to both Piedmont and other third parties. Sales to Piedmont are for the greater of 113,000 metric tons per year or 50% of annual production ranging from $500 to $900 per ton; whereas, sales to third parties of Sayona Quebec are at market pricing.

The Quebec/Authier feasibility study dated November 11, 2019, uses a concentrate sales price of $693/ton, which appears to be materially inconsistent with the contractual price at which NAL will purchase output from the project which, according to the NAL pre-feasibility study dated May 23, 2022, is $205/ton.

We advise the Staff that the 2019 Quebec/Authier feasibility study was published prior to Sayona Quebec’s acquisition of NAL and therefore does not represent the current business model of Sayona Quebec. In May 2022, Sayona Quebec published the Quebec/Sayona NAL feasibility study, which superseded the 2019 Quebec/Authier feasibility study. Sayona Quebec’s strategy under the 2019 Quebec/Authier feasibility study was to develop a mine and a spodumene concentrator at Authier. When Sayona Quebec acquired NAL in August 2021, Sayona Quebec’s business strategy changed to developing Authier as a mine only and to transport Authier’s run-of-mine ore to NAL for blending as feed for the NAL concentrator. Pricing disclosed in the May 2022 feasibility study is the transfer price used for transferring ore from Authier to the concentrator site.

The resources of 30.1 Mt associated with the Ghana project does not reconcile with reserves of 18.9 Mt in the corresponding pre-feasibility study dated September 22, 2022; while the production schedule associated with the $1.3 billion NPV detail appears to include about 24.5% inferred resources, which would not be permissible in establishing reserve economics due to low levels of confidence.

We concur with the Staff’s comment and in our future presentations, we will separate measured and indicated mineral resources from inferred resources and will not provide totals of such resources.

The Ewoyaa feasibility study published by Atlantic Lithium Limited (“Atlantic Lithium”) includes inferred mineral resources within its production schedule. Atlantic Lithium also provides the following cautionary statement with respect to the results of the study:

The production targets referred to in this PFS announcement are based on an initial 12.5-year mining plan comprising 75.5% of Indicated Resources and 24.5% of Inferred Resources modelled from the JORC Mineral Resource Estimate released on AIM on 24 March 2022. It is noted that 9.2% of the Inferred Resources are mined within the first 24 months of the PFS mining schedule, this due to drilling access restrictions at the time of the Mineral Resource estimate, which will be resolved as part of the current in-fill drilling programme.

There is a low level of geological confidence associated with Inferred Mineral Resources and there is no certainty that further exploration work will result in the determination of Indicated Mineral Resources or that the production target itself will be realised.

The Inferred Mineral Resource is not the determining factor in the viability of the Ewoyaa Lithium Project as the Inferred Mineral Resource represents only 9.2% of the processed ore during the first 24 months of production, with a short pay-back period of 5 months. Additionally, even with Inferred Resources deferred to waste, and all mining and processing costs carried over life of mine for the Inferred Resources, the Project remains cash-flow positive on an annualised basis.

The mineralisation at Ewoyaa has been confirmed to be associated with spodumene bearing pegmatite as the main lithium bearing mineral. No significant petalite or lepidolite has been observed. The deposits show good continuity of the main mineralised units which provided for drill hole intersections to be modelled into coherent, geologically robust domains.

Consistency is evident in the thickness of the structure, and the distribution of grade appears to be reasonable along and across strike.

It is considered that there are reasonable grounds for the conversion of Inferred to Indicated or Measured Resource status, providing reasonable confidence that the production targets outlined in the PFS will be achievable.

Atlantic Lithium recently announced an updated mineral resource estimate in which the majority of mineral resources in the inferred category for Ewoyaa have been upgraded to the indicated category. Additionally, Atlantic Lithium has estimated measured mineral resources.

The measured mineral resources at Ewoyaa are now 3.5 Mt at 1.37% Li2O with indicated mineral resources estimated at 24.5 Mt at 1.25% Li2O. The mineral resources together approach the production target outlined in the feasibility study (30.1 Mt at 1.26% Li2O).

Atlantic Lithium expects to complete a feasibility study for Ewoyaa in July 2023 with a further update to the mineral reserves of the project.

In our future presentations, we will make the following modifications:

-

With respect to disclosures regarding the current pre-feasibility study results, we will include the full cautionary statement made by Atlantic Lithium associated with its inclusion of inferred mineral resources in the production target; and

-

Upon Atlantic Lithium’s planned completion of its feasibility study in July 2023, we will update production targets to separately disclose estimates of mineral reserves.

We will continue to disclose these resources as prepared in accordance with the JORC Code.

The Tennessee PEA, associated with your $2.2 billion NPV detail, indicates you would purchase 196,000 tons per year spodumene concentrate (SC6) and produce 30,000 tons of lithium hydroxide per year, although without indicating the sources of SC6 considering your contractual commitments with Tesla and LG.

We advise the Staff that we do not believe our offtake supply agreements with Tesla and LG will adversely affect our ability to supply spodumene concentrate to Tennessee Lithium.

We have the right to purchase 50% of Atlantic Lithium’s production of spodumene concentrate from its Ewoyaa project in Ghana at market prices on a life-of-mine basis. Piedmont currently contemplates utilizing spodumene concentrate from this offtake agreement as partial feed for its proposed Tennessee Lithium hydroxide plant.

Based on Atlantic Lithium’s current estimated production target, our offtake right equates to 127,500 tons per year of spodumene concentrate.

Our offtake supply agreement with Tesla for NAL spodumene concentrate currently runs through the end of 2025. After December 31, 2025, an additional 60,000 metric tons annually of spodumene concentrate may be delivered from NAL to Tennessee Lithium. We do not expect to require this material to supplement our supply requirements until 2026, at the earliest, based on the estimated startup date of our Tennessee Lithium operation and its expected ramp up period.

We believe the relatively modest volumes required to feed our initial Tennessee Lithium operations could be sourced from remaining NAL offtake rights, from Carolina Lithium upon its start of operations, or from other market sources. If for any reason Piedmont does not exercise our rights to these offtake supplies, the Company is confident that alternative sources of spodumene concentrate would be available to feed Tennessee Lithium’s facility, as current and future spodumene producers seek to feed the growing U.S. electric vehicle market and qualify for the benefits available under the Inflation Reduction Act of 2022.

Please describe any efforts that you had previously undertaken to validate the information and describe any internal controls that you will establish to ensure that any similar details in future presentations is accurate and consistent with the guidance governing the reporting of comparable information in your periodic filings.

Response:

The Company has processes in place over information included in investor presentations as noted below:

Obtain information directly from

Show Raw Text
CORRESP
1
filename1.htm

    VIA EDGAR SUBMISSION

    Mr. John Coleman and Mr. Gus Rodriguez

    Division of Corporation Finance

    Office of Energy & Transportation

    Securities and Exchange Commission

    100 F Street NE

    Washington, D.C. 20549

    March 17, 2023

          Re:

            Piedmont Lithium Inc.

    Form 10-KT for the Six Months Ended December 31, 2021

    Filed February 28, 2022

    File No. 001-38427

    Dear Mr. Coleman and Mr. Rodriguez,

    Please find our response to the comments set forth in a letter dated March 6, 2023 (the “Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating
      to the above-mentioned Transition Report on Form 10-KT for the six months ended December 31, 2021 (the “2021 10-KT”).  References to the “Company,” “Piedmont,” “we,” “us” and “our” in this letter refer to Piedmont Lithium Inc., unless
      otherwise indicated.

    Our Technical Report Summary (the “Original TRS”) was originally filed as an exhibit to the 2021 10-KT.  On March 1, 2023, we filed an amendment to the Original TRS (as amended, the “Amended TRS”) as an
      exhibit to our Form 10-K for the year ended December 31, 2022 (our “2022 10-K”).  We will file a further revised TRS (the “Revised TRS”), reflecting the comments provided by the Staff in its Letter (other than Comment 1), as an exhibit
      to an amendment to our Form 10-K for the year ended December 31, 2022.

    For your convenience, we have restated below in bold each comment from the Letter and supplied our responses immediately thereafter.  Unless otherwise indicated, all references in this letter to “$” are to United
      States dollars.

    Form 10-KT for the Fiscal Year ended December 31, 2021

    General

          1.

            We note that you filed approximately seven current reports on Form 8-K over the past year to alert investors to corporate presentations that you have posted on your website, in which you have
              reported economic details for several projects.  For example, the January 27, 2023 and February 24, 2023 presentations include a summary of economic details, including mineralization, for the Quebec, Ghana, Tennessee Lithium, and Carolina
              Lithium projects on pages 8 and 7, respectively.

      You include a similar summary in each of the presentations posted during this timeframe and have similar, related, or corresponding details on other pages within your presentations.  In footnotes
        on the summary pages, you identify various announcements and technical reports from which you have sourced some of the details.

    As we discussed during our phone conference on February 28, 2023, numerous details presented on these pages appear to diverge from disclosure standards that
      govern reporting in your periodic reports, such as Item 1300 of Regulation S-K, and Rule 12b-20 of Regulation 12B.  For example, we note the following apparent inconsistencies with these requirements that you will need to address.

          •

            The pre-feasibility project stage associated with the projects does not appear to be consistent with reporting resources rather than reserves for the projects.

          •

            The quantifications of resources for one or more projects appear to reflect summations of inferred resources with other classifications of resources or reserves, which is generally and commonly not permissible
              due to the low level of confidence associated with estimates of inferred resources.

          •

            The 119.1 Mt resource associated with Quebec does not reconcile with reserves of 29.2 Mt for NAL and 12.1 Mt for Authier.

          •

            The Quebec/Sayona NAL feasibility study dated May 23, 2022, associated with your $571 million NPV detail, uses a concentrate sales price of $1,242 per ton, which appears to be materially inconsistent with the
              contractual price at which you will purchase output disclosed as ranging from $500 to $900 per ton.

          •

            The Quebec/Authier feasibility study dated November 11, 2019, uses a concentrate sales price of $693/ton, which appears to be materially inconsistent with the contractual price at which NAL will purchase output
              from the project which, according to the NAL pre-feasibility study dated May 23, 2022, is $205/ton.

          •

            The resources of 30.1 Mt associated with the Ghana project does not reconcile with reserves of 18.9 Mt in the corresponding pre-feasibility study dated September 22, 2022; while the production schedule associated
              with the $1.3 billion NPV detail appears to include about 24.5% inferred resources, which would not be permissible in establishing reserve economics due to low levels of confidence.

          •

            The Tennessee PEA, associated with your $2.2 billion NPV detail, indicates you would purchase 196,000 tons per year spodumene concentrate (SC6) and produce 30,000 tons of lithium hydroxide per year, although
              without indicating the sources of SC6 considering your contractual commitments with Tesla and LG.

    Tell us whether you concur with each of the observations listed above and if there are any points with which you do not agree, tell us you position and
      describe your rationale.

    Response 1:

    We acknowledge the Staff’s comment. We further advise the Staff that we will undertake the actions described below in response, as applicable, to the Staff’s observations, which
      are restated below in bold.

          •

            The pre-feasibility project stage associated with the projects does not appear to be consistent with reporting resources rather than reserves for the projects.

      We concur with the Staff’s comment and in our future presentations, we will disclose mineral reserves for these projects to the extent supported by a pre-feasibility or feasibility level of study.

          •

            The quantifications of resources for one or more projects appear to reflect summations of inferred resources with other classifications of resources or reserves, which is generally and commonly not permissible
              due to the low level of confidence associated with estimates of inferred resources.

      We concur with the Staff’s comment and in our future presentations, we will separate measured and indicated mineral resources from inferred resources, and will not provide totals of such resources.

          •

            The 119.1 Mt resource associated with Quebec does not reconcile with reserves of 29.2 Mt for NAL and 12.1 Mt for Authier.

      We concur with the Staff’s comment and in our future presentations, we will show mineral reserves in our project summaries, to the extent declared, and provide a reconciliation of mineral reserves to mineral resources
        for each project.

          •

            The Quebec/Sayona NAL feasibility study dated May 23, 2022, associated with your $571 million NPV detail, uses a concentrate sales price of $1,242 per ton, which appears to be materially inconsistent with the
              contractual price at which you will purchase output disclosed as ranging from $500 to $900 per ton.

      We advise the Staff that the concentrate sales price assumed by Sayona Quebec in its Quebec/Sayona NAL feasibility study represents a blended average of concentrate sales to both Piedmont and other third
        parties. Sales to Piedmont are for the greater of 113,000 metric tons per year or 50% of annual production ranging from $500 to $900 per ton; whereas, sales to third parties of Sayona Quebec are at market pricing.

          •

            The Quebec/Authier feasibility study dated November 11, 2019, uses a concentrate sales price of $693/ton, which appears to be materially inconsistent with the contractual price at which NAL will purchase output
              from the project which, according to the NAL pre-feasibility study dated May 23, 2022, is $205/ton.

      We advise the Staff that the 2019 Quebec/Authier feasibility study was published prior to Sayona Quebec’s acquisition of NAL and therefore does not represent the current business model of Sayona Quebec.
        In May 2022, Sayona Quebec published the Quebec/Sayona NAL feasibility study, which superseded the 2019 Quebec/Authier feasibility study.  Sayona Quebec’s strategy under the 2019 Quebec/Authier feasibility study was to develop a mine and a
        spodumene concentrator at Authier.  When Sayona Quebec acquired NAL in August 2021, Sayona Quebec’s business strategy changed to developing Authier as a mine only and to transport Authier’s run-of-mine ore to NAL for blending as feed for the NAL
        concentrator.  Pricing disclosed in the May 2022 feasibility study is the transfer price used for transferring ore from Authier to the concentrator site.

          •

            The resources of 30.1 Mt associated with the Ghana project does not reconcile with reserves of 18.9 Mt in the corresponding pre-feasibility study dated September 22, 2022; while the production schedule associated
              with the $1.3 billion NPV detail appears to include about 24.5% inferred resources, which would not be permissible in establishing reserve economics due to low levels of confidence.

      We concur with the Staff’s comment and in our future presentations, we will separate measured and indicated mineral resources from inferred resources and will not provide totals of such resources.

    The Ewoyaa feasibility study published by Atlantic Lithium Limited (“Atlantic Lithium”) includes inferred mineral resources within its production schedule.  Atlantic Lithium also provides the
      following cautionary statement with respect to the results of the study:

    The production targets referred to in this PFS announcement are based on an initial 12.5-year mining plan comprising 75.5% of Indicated Resources and 24.5% of
      Inferred Resources modelled from the JORC Mineral Resource Estimate released on AIM on 24 March 2022.  It is noted that 9.2% of the Inferred Resources are mined within the first 24 months of the PFS mining schedule, this due to drilling access
      restrictions at the time of the Mineral Resource estimate, which will be resolved as part of the current in-fill drilling programme.

    There is a low level of geological confidence associated with Inferred Mineral Resources and there is no certainty that further exploration work will result in
      the determination of Indicated Mineral Resources or that the production target itself will be realised.

    The Inferred Mineral Resource is not the determining factor in the viability of the Ewoyaa Lithium Project as the Inferred Mineral Resource represents only
      9.2% of the processed ore during the first 24 months of production, with a short pay-back period of 5 months.  Additionally, even with Inferred Resources deferred to waste, and all mining and processing costs carried over life of mine for the
      Inferred Resources, the Project remains cash-flow positive on an annualised basis.

    The mineralisation at Ewoyaa has been confirmed to be associated with spodumene bearing pegmatite as the main lithium bearing mineral.  No significant petalite
      or lepidolite has been observed.  The deposits show good continuity of the main mineralised units which provided for drill hole intersections to be modelled into coherent, geologically robust domains.

    Consistency is evident in the thickness of the structure, and the distribution of grade appears to be reasonable along and across strike.

    It is considered that there are reasonable grounds for the conversion of Inferred to Indicated or Measured Resource status, providing reasonable confidence
      that the production targets outlined in the PFS will be achievable.

    Atlantic Lithium recently announced an updated mineral resource estimate in which the majority of mineral resources in the inferred category for Ewoyaa have been upgraded to the indicated category.
      Additionally, Atlantic Lithium has estimated measured mineral resources.

    The measured mineral resources at Ewoyaa are now 3.5 Mt at 1.37% Li2O with indicated mineral resources estimated at 24.5 Mt at 1.25% Li2O.  The mineral resources together
      approach the production target outlined in the feasibility study (30.1 Mt at 1.26% Li2O).

    Atlantic Lithium expects to complete a feasibility study for Ewoyaa in July 2023 with a further update to the mineral reserves of the project.

    In our future presentations, we will make the following modifications:

              -

              With respect to disclosures regarding the current pre-feasibility study results, we will include the full cautionary statement made by Atlantic Lithium associated with its inclusion of inferred mineral resources
                in the production target; and

              -

              Upon Atlantic Lithium’s planned completion of its feasibility study in July 2023, we will update production targets to separately disclose estimates of mineral reserves.

    We will continue to disclose these resources as prepared in accordance with the JORC Code.

          •

            The Tennessee PEA, associated with your $2.2 billion NPV detail, indicates you would purchase 196,000 tons per year spodumene concentrate (SC6) and produce 30,000 tons of lithium hydroxide per year, although
              without indicating the sources of SC6 considering your contractual commitments with Tesla and LG.

      We advise the Staff that we do not believe our offtake supply agreements with Tesla and LG will adversely affect our ability to supply spodumene concentrate to Tennessee Lithium.

    We have the right to purchase 50% of Atlantic Lithium’s production of spodumene concentrate from its Ewoyaa project in Ghana at market prices on a life-of-mine basis. Piedmont currently contemplates
      utilizing spodumene concentrate from this offtake agreement as partial feed for its proposed Tennessee Lithium hydroxide plant.

    Based on Atlantic Lithium’s current estimated production target, our offtake right equates to 127,500 tons per year of spodumene concentrate.

    Our offtake supply agreement with Tesla for NAL spodumene concentrate currently runs through the end of 2025.  After December 31, 2025, an additional 60,000 metric tons annually of spodumene
      concentrate may be delivered from NAL to Tennessee Lithium.  We do not expect to require this material to supplement our supply requirements until 2026, at the earliest, based on the estimated startup date of our Tennessee Lithium operation and its
      expected ramp up period.

    We believe the relatively modest volumes required to feed our initial Tennessee Lithium operations could be sourced from remaining NAL offtake rights, from Carolina Lithium upon its start of
      operations, or from other market sources. If for any reason Piedmont does not exercise our rights to these offtake supplies, the Company is confident that alternative sources of spodumene concentrate would be available to feed Tennessee Lithium’s
      facility, as current and future spodumene producers seek to feed the growing U.S. electric vehicle market and qualify for the benefits available under the Inflation Reduction Act of 2022.

    Please describe any efforts that you had previously undertaken to validate the information and describe any internal controls that you will establish to ensure
      that any similar details in future presentations is accurate and consistent with the guidance governing the reporting of comparable information in your periodic filings.

    Response:

    The Company has processes in place over information included in investor presentations as noted below:

              •

              Obtain information directly from