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Re: pitboss22 post# 853

Monday, 06/04/2012 1:12:37 AM

Monday, June 04, 2012 1:12:37 AM

Post# of 3962
They clearly do not have "proven reserves" as they have not met the legal requirements for proven reserves.

Let me give you an example of an SEC Comment Letter sent to another non-compliant exploration-stage company that illegally claimed to have "proven reserves".

"We note your consulting geologist provided reserve estimates. Please note that mineral reserves for a mineral property may not be designated unless:

• Competent professional engineers conduct a detailed engineering and economic study, and the “bankable” or “final” feasibility study demonstrates that a mineral deposit can be mined profitably at a commercial rate.
• Historic three-year average commodity price is used in any reserve or cash flow analysis used to designate reserves.
• The company has demonstrated that the mineral property will receive its governmental permits, and the primary environmental document has been filed with the appropriate governmental authorities.

Please revise your disclosure accordingly. In addition, please revise your disclosure throughout this document to ensure you do not prematurely indicate mining operations on mining properties before a proper feasibility study and economic viability determination has been conducted."

A bankable feasibility study is not a minor thing. The size and complexity varies by the size and type of deposit, but typically it requires years of work by numerous experts conducting an enormous amount of work (not only exploration to define the resource and grade, but also metallurgical/processing studies to determine the most efficient and cost-effective mining and processing methods, mine design and related engineering studies, environmental studies, including hydrology and animal studies, reclamation studies and plans, just to name a few). And millions and millions of dollars to pay for all the studies that go into a bankable feasibility. Once all of that is taken into consideration, a final feasibility study is a pretty weighty document - hundreds of pages long.

Needless to say, drilling 5 holes and calling it a "proven reserve" is a bad joke.
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