Medinah Minerals (MDMN)

[Hurricane_Rick]

Hi Anvil,

Yes I do realize that mining companies that are SEC filers are subject to the requirements guidelines in SEC Industry Guide 7. However, MDMN is not an SEC filer, so I'm not sure that Industry Guide 7 requirements apply to them as a non-filer - Not unlike non-filers not being required to file audited financials, list insider transactions, and a whole host of other requirements the SEC requires from its fully reporting issuers. In the past I had searched for occurrences or SEC opinion letters related to non-filers being subject to Industry Guide 7 requirements. To date I haven't found any. Obviously that doesn't mean they don't exist. I'm willing to be corrected if someone can find an example or an opinion letter from the SEC related to Industry Guide 7 applying to non-filers. And if so, I would forward it immediately to the company.

To be clear, I'm not defending or condoning the company's use of the terms - I'm only making the observation that they may not be subject to the Industry Guide 7 rules that you pointed out. FWIW, I have previously contacted the company cautioning their use of certain mining terms that have specific meaning within the context of NI 43-101 or Industry Guide 7.