SEC Comment Letter 0000000000-23-008063 to Diversified Energy Co (DEC)
Diversified Energy Co
Date: July 27, 2023 · CIK: 0001922446 · Accession: 0000000000-23-008063
AI Filing Summary & Sentiment
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Letter
United States securities and exchange commission logo July 27, 2023 Benjamin Sullivan Executive Vice President, General Counsel and Corporate Secretary Diversified Energy Co PLC 1600 Corporate Drive Birmingham, Alabama 35242 Re:Diversified Energy Company plc Amendment No. 5 to Draft Registration Statement on Form F-1 Submitted July 17, 2023 CIK No. 0001922446 Dear Benjamin Sullivan: We have reviewed your amended draft registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 5 to Draft Registration Statement on Form F-1 Exhibits 1.The disclosures in Exhibit 99.1 do not appear to address all of the reserve report requirements pursuant to Item 1202(a)(8) of Regulation S-K. Please obtain and file a revised reserve report to include disclosure addressing the following points: 1.The purpose for which the report was prepared, e.g. for inclusion as an exhibit in a filing made with the U.S. Securities and Exchange Commission, per Item 1202(a)(8)(i). 2.A statement that the assumptions, data, methods, and procedures are appropriate for the purpose served by the report per Item 1202(a)(8)(iv).
FirstName LastNameBenjamin Sullivan Comapany NameDiversified Energy Co PLC July 27, 2023 Page 2 FirstName LastName Benjamin Sullivan Diversified Energy Co PLC July 27, 2023 Page 2 You may contact Jennifer O'Brien, Staff Accountant, at 202-551-3721 or Shannon Buskirk, Staff Accountant, at 202-551-3717 if you have questions regarding comments on the financial statements and related matters. You may contact Sandra Wall, Petroleum Engineer, at 202-551-4727 or John Hodgin, Petroleum Engineer, at 202-551-3699 with questions about engineering comments. Please contact Irene Barberena-Meissner, Staff Attorney, at 202- 5516548 or Kevin Dougherty, Staff Attorney, at 202-551-3271 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Ryan J. Lynch, Esq.
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United States securities and exchange commission logo
July 27, 2023
Benjamin Sullivan
Executive Vice President, General Counsel and Corporate Secretary
Diversified Energy Co PLC
1600 Corporate Drive
Birmingham, Alabama 35242
Re:Diversified Energy Company plc
Amendment No. 5 to Draft Registration Statement on Form F-1
Submitted July 17, 2023
CIK No. 0001922446
Dear Benjamin Sullivan:
We have reviewed your amended draft registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 5 to Draft Registration Statement on Form F-1
Exhibits
1.The disclosures in Exhibit 99.1 do not appear to address all of the reserve report
requirements pursuant to Item 1202(a)(8) of Regulation S-K. Please obtain and file a
revised reserve report to include disclosure addressing the following points:
1.The purpose for which the report was prepared, e.g. for inclusion as an exhibit in a
filing made with the U.S. Securities and Exchange Commission, per Item
1202(a)(8)(i).
2.A statement that the assumptions, data, methods, and procedures are appropriate for
the purpose served by the report per Item 1202(a)(8)(iv).
FirstName LastNameBenjamin Sullivan
Comapany NameDiversified Energy Co PLC
July 27, 2023 Page 2
FirstName LastName
Benjamin Sullivan
Diversified Energy Co PLC
July 27, 2023
Page 2
You may contact Jennifer O'Brien, Staff Accountant, at 202-551-3721 or Shannon
Buskirk, Staff Accountant, at 202-551-3717 if you have questions regarding comments on the
financial statements and related matters. You may contact Sandra Wall, Petroleum Engineer, at
202-551-4727 or John Hodgin, Petroleum Engineer, at 202-551-3699 with questions about
engineering comments. Please contact Irene Barberena-Meissner, Staff Attorney, at 202-
5516548 or Kevin Dougherty, Staff Attorney, at 202-551-3271 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: Ryan J. Lynch, Esq.