SEC Comment Letter 0000000000-25-008727 to Electra Battery Materials Corp (ELBM)
Electra Battery Materials Corp
Date: Aug. 18, 2025 · CIK: 0001907184 · Accession: 0000000000-25-008727
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-288364
Letter
August 18, 2025 Trent Mell Chief Executive Officer Electra Battery Materials Corporation 133 Richmond Street W, Suite 602 Toronto, ON M5H 2L3 Canada Re:Electra Battery Materials Corporation Amendment No. 2 to Registration Statement on Form F-3 Filed August 11, 2025 File No. 333-288364 Dear Trent Mell: We have reviewed your amended 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. Unless we note otherwise, any references to prior comments are to comments in our August 6, 2025 letter. Amendment No. 2 to Registration Statement on Form F-3 General 1.We note your statement in your revised explanatory note that “[t]his Amendment No. 2 does not reflect events occurring after the filing of the Original Filing” on June 27, 2025 and “does not modify or update the disclosure therein in any way except as described above.” Please remove such statement from your explanatory note and update your prospectus disclosure accordingly. Refer to Form F-3.
August 18, 2025 Page 2 2.We note that on August 15, 2025 you provided in a report on Form 6-K your interim financial statements for the six months ended June 30, 2025. Please revise your registration statement to provide such interim financial information in your prospectus, or to incorporate such interim financial information by reference. Refer to Item 5(b)(2) of Form F-3 and Item 8.A.5 of Form 20-F. Refer also to Item 6(c) of Form F-3. 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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August 18, 2025
Trent Mell
Chief Executive Officer
Electra Battery Materials Corporation
133 Richmond Street W, Suite 602
Toronto, ON M5H 2L3
Canada
Re:Electra Battery Materials Corporation
Amendment No. 2 to Registration Statement on Form F-3
Filed August 11, 2025
File No. 333-288364
Dear Trent Mell:
We have reviewed your amended 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. Unless we note
otherwise, any references to prior comments are to comments in our August 6, 2025 letter.
Amendment No. 2 to Registration Statement on Form F-3
General
1.We note your statement in your revised explanatory note that “[t]his Amendment No.
2 does not reflect events occurring after the filing of the Original Filing” on June 27,
2025 and “does not modify or update the disclosure therein in any way except as
described above.” Please remove such statement from your explanatory note and
update your prospectus disclosure accordingly. Refer to Form F-3.
August 18, 2025
Page 2
2.We note that on August 15, 2025 you provided in a report on Form 6-K your interim
financial statements for the six months ended June 30, 2025. Please revise your
registration statement to provide such interim financial information in your
prospectus, or to incorporate such interim financial information by reference. Refer to
Item 5(b)(2) of Form F-3 and Item 8.A.5 of Form 20-F. Refer also to Item 6(c) of
Form F-3.
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