SEC Comment Letter 0000000000-24-001633 to ioneer Ltd (IONR, GSCCF) (CIK 0001896084) (IONR)
ioneer Ltd (IONR, GSCCF) (CIK 0001896084)
Date: Feb. 29, 2024 · CIK: 0001896084 · Accession: 0000000000-24-001633
AI Filing Summary & Sentiment
File numbers found in text: 001-41412
Letter
United States securities and exchange commission logo February 12, 2024 Bernard Rowe Chief Executive Officer Ioneer Ltd Suite 5.03, Level 5 140 Arthur Street North Sydney, NSW 2060 Australia Re:Ioneer Ltd Form 20-F for the Fiscal Year Ended June 30, 2023 Filed October 27, 2023 File No. 001-41412 Dear Bernard Rowe: We have reviewed your filing and have the following comments. 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. Form 20-F for the Fiscal Year Ended June 30, 2023 Item 4. Information on the Company, page 26 1.We note that your mineral resources have changed from those reported in your 20-F filing for the fiscal year ended June 30, 2022. Item 1304(e) of Regulation S-K requires a comparison of a property's mineral resources and reserves as of the end of the last fiscal year with the mineral resources and reserves as of the end of the proceeding fiscal year, and an explanation of any material change between the two. Please revise subsequent 20- F filings to include the information required by Item 1304(e) of Regulation S-K. 2.Please revise subsequent 20-F filings to include the point of reference with respect to your mineral resources and mineral reserves as required by Item 1304(d)(1) of Regulation S-K, or tell us where this information is located in your filing.
FirstName LastNameBernard Rowe Comapany NameIoneer Ltd February 12, 2024 Page 2 FirstName LastName Bernard Rowe Ioneer Ltd February 12, 2024 Page 2 3.We note that you have reported each class of mineral resource (measured, indicated, and inferred). In subsequent filings please revise to also report total measured and indicated resources (measured plus indicated) as required by Item 1304(d)(1) of Regulation S-K. Inferred resources should not be totaled with measured and indicated resources consistent with Item 1304(d)(1). We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. 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: Eric Scarazzo
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United States securities and exchange commission logo
February 12, 2024
Bernard Rowe
Chief Executive Officer
Ioneer Ltd
Suite 5.03, Level 5
140 Arthur Street
North Sydney, NSW 2060
Australia
Re:Ioneer Ltd
Form 20-F for the Fiscal Year Ended June 30, 2023
Filed October 27, 2023
File No. 001-41412
Dear Bernard Rowe:
We have reviewed your filing and have the following comments.
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.
Form 20-F for the Fiscal Year Ended June 30, 2023
Item 4. Information on the Company, page 26
1.We note that your mineral resources have changed from those reported in your 20-F filing
for the fiscal year ended June 30, 2022. Item 1304(e) of Regulation S-K requires a
comparison of a property's mineral resources and reserves as of the end of the last fiscal
year with the mineral resources and reserves as of the end of the proceeding fiscal year,
and an explanation of any material change between the two. Please revise subsequent 20-
F filings to include the information required by Item 1304(e) of Regulation S-K.
2.Please revise subsequent 20-F filings to include the point of reference with respect to your
mineral resources and mineral reserves as required by Item 1304(d)(1) of Regulation S-K,
or tell us where this information is located in your filing.
FirstName LastNameBernard Rowe
Comapany NameIoneer Ltd
February 12, 2024 Page 2
FirstName LastName
Bernard Rowe
Ioneer Ltd
February 12, 2024
Page 2
3.We note that you have reported each class of mineral resource (measured, indicated, and
inferred). In subsequent filings please revise to also report total measured and indicated
resources (measured plus indicated) as required by Item 1304(d)(1) of Regulation S-K.
Inferred resources should not be totaled with measured and indicated resources consistent
with Item 1304(d)(1).
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
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: Eric Scarazzo