SEC Comment Letter 0000000000-25-007652 to Electra Battery Materials Corp (ELBM)
Electra Battery Materials Corp
Date: July 21, 2025 · CIK: 0001907184 · Accession: 0000000000-25-007652
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-288364
Letter
July 21, 2025 Trent Mell Chief Executive Officer Electra Battery Materials Corp 133 Richmond Street W, Suite 602 Toronto, ON M5H 2L3 Canada Re:Electra Battery Materials Corp Registration Statement on Form F-3 Filed June 27, 2025 File No. 333-288364 Dear Trent Mell: We have conducted a limited review of your registration statement and have the following comments. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Registration Statement on Form F-3 Signatures, page II-6 1.Please ensure that you have provided all signatures required by Form F-3. For example, we note that you have not provided a signature for C.L. “Butch” Otter or a full signature for Alden Greenhouse. Exhibits 2.Please obtain and file an opinion that opines on the legality of the common shares that may be issued pursuant to the "at the market" offering prospectus supplement.
July 21, 2025 Page 2 General 3.Please confirm your understanding that we will not be in a position to take action to accelerate the effectiveness of your registration statement until our comments relating to your Form 20-F for the fiscal year ended December 31, 2024 have been resolved. 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. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Michael Purcell at 202-551-5351 or Laura Nicholson at 202-551-3584 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc:Thomas Rose
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July 21, 2025
Trent Mell
Chief Executive Officer
Electra Battery Materials Corp
133 Richmond Street W, Suite 602
Toronto, ON M5H 2L3
Canada
Re:Electra Battery Materials Corp
Registration Statement on Form F-3
Filed June 27, 2025
File No. 333-288364
Dear Trent Mell:
We have conducted a limited review of your registration statement and have the
following comments.
Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement on Form F-3
Signatures, page II-6
1.Please ensure that you have provided all signatures required by Form F-3. For
example, we note that you have not provided a signature for C.L. “Butch” Otter or a
full signature for Alden Greenhouse.
Exhibits
2.Please obtain and file an opinion that opines on the legality of the common shares that
may be issued pursuant to the "at the market" offering prospectus supplement.
July 21, 2025
Page 2
General
3.Please confirm your understanding that we will not be in a position to take action to
accelerate the effectiveness of your registration statement until our comments relating
to your Form 20-F for the fiscal year ended December 31, 2024 have been resolved.
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Michael Purcell at 202-551-5351 or Laura Nicholson at 202-551-3584
with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Thomas Rose