SEC Comment Letter 0000000000-24-007299 to Snow Lake Resources Ltd. (LITM) (CIK 0001769697) (LITM)
Snow Lake Resources Ltd. (LITM) (CIK 0001769697)
Date: June 28, 2024 · CIK: 0001769697 · Accession: 0000000000-24-007299
AI Filing Summary & Sentiment
File numbers found in text: 001-41085
Letter
United States securities and exchange commission logo June 28, 2024 Frank Wheatley Chief Executive Officer Snow Lake Resources Ltd. 360 Main St 30th Floor Winnipeg, MB R3C 0V1 Canada Re:Snow Lake Resources Ltd. Form 20-F for the Fiscal Year Ended June 30, 2023 Filed October 31, 2023 File No. 001-41085 Dear Frank Wheatley: We have reviewed your May 30, 2024 response to our comment letter and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our April 19, 2024 letter. Form 20-F/A for the Fiscal Year Ended June 30, 2023 General 1.We note your response to comment 4. Among other items in your response, you state that you no longer consider the Snow Lake Lithium project to be material, and that the project does not have the scale, size, grade or project economics to make it an attractive development project. We further note that you significantly reduced spending on the project based on your belief that expending any additional funds on continued exploration on the project would not create any shareholder value. We understand that you will assess the property for impairments in Q4 with the potential for a significant write-down of the asset and are focused on pursuing other projects.
FirstName LastNameFrank Wheatley Comapany NameSnow Lake Resources Ltd. June 28, 2024 Page 2 FirstName LastName Frank Wheatley Snow Lake Resources Ltd. June 28, 2024 Page 2 Considering the foregoing, please reconcile your response with certain language contained in your press releases. For example, under the “About Snow Lake Resources Ltd” caption in Exhibit 99.1 of your Form 6-K filed June 21, 2024, you include language regarding the Snow Lake Property that appears to be contrary to your response, such as the “Snow Lake Lithium Project being an advanced stage exploration project” …and that you “are focused on advancing all projects.” In light of your response to comment 4, please tell us if this language will be revised.
Additionally, considering the previous significant expenditures on the Snow Lake Lithium Project, please tell us your plans, if any, for communicating with shareholders regarding your assessment of materiality of the project. For example, tell us if you anticipate filing a 6-K with respect to the status of the project. Please contact John Coleman at 202-551-3610 or Craig Arakawa at 202-551-3650 if you have questions regarding comments Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Daniel Nauth
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United States securities and exchange commission logo
June 28, 2024
Frank Wheatley
Chief Executive Officer
Snow Lake Resources Ltd.
360 Main St 30th Floor
Winnipeg, MB R3C 0V1
Canada
Re:Snow Lake Resources Ltd.
Form 20-F for the Fiscal Year Ended June 30, 2023
Filed October 31, 2023
File No. 001-41085
Dear Frank Wheatley:
We have reviewed your May 30, 2024 response to our comment letter and have the
following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our April 19,
2024 letter.
Form 20-F/A for the Fiscal Year Ended June 30, 2023
General
1.We note your response to comment 4. Among other items in your response, you state that
you no longer consider the Snow Lake Lithium project to be material, and that the project
does not have the scale, size, grade or project economics to make it an attractive
development project. We further note that you significantly reduced spending on the
project based on your belief that expending any additional funds on continued exploration
on the project would not create any shareholder value. We understand that you will assess
the property for impairments in Q4 with the potential for a significant write-down of the
asset and are focused on pursuing other projects.
FirstName LastNameFrank Wheatley
Comapany NameSnow Lake Resources Ltd.
June 28, 2024 Page 2
FirstName LastName
Frank Wheatley
Snow Lake Resources Ltd.
June 28, 2024
Page 2
Considering the foregoing, please reconcile your response with certain language contained
in your press releases. For example, under the “About Snow Lake Resources Ltd” caption
in Exhibit 99.1 of your Form 6-K filed June 21, 2024, you include language regarding the
Snow Lake Property that appears to be contrary to your response, such as the “Snow Lake
Lithium Project being an advanced stage exploration project” …and that you “are focused
on advancing all projects.” In light of your response to comment 4, please tell us if this
language will be revised.
Additionally, considering the previous significant expenditures on the Snow Lake Lithium
Project, please tell us your plans, if any, for communicating with shareholders regarding
your assessment of materiality of the project. For example, tell us if you anticipate filing a
6-K with respect to the status of the project.
Please contact John Coleman at 202-551-3610 or Craig Arakawa at 202-551-3650 if you
have questions regarding comments
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: Daniel Nauth