Medinah Minerals (MDMN)

[Hurricane_Rick]

Anvil,

On the other side, don't want to rain on anyone's parade. But, in fact, MDMN has illegally reported reserves, among other indiscretions

You mention "in fact", but I've yet to see any facts that support your statements on the matter. If this is not just your opinion, can you please cite any case law, legal opinion or SEC action that prohibited, fined or otherwise compelled some sort of legal or procedural action against a non-filing mining company with regards to SEC Industry Guide 7 requirements such as mentioning "reserves" in its corporate literature? I've been looking, but haven't found anything. This leads me to believe that this notion you are putting forth is an opinion/assumption. I have stated in a previous (unaddressed) post to you in this thread that I believe (though I'm not sure), that non-SEC filers are not subject to the SEC's Industry Guide 7 requirements...similar to how non-filers are not required to report insider transactions, audited financials and so forth.

Supporting that opinion, I have found text and legal opinions that clearly indicate that the Industry Guide 7 applies specifically to SEC filers:

For example, from the SEC's Industry Guide itself (Page 34):

"Definitions.
The following definitions apply to registrants engaged or to be engaged in significant mining operations"

And from Hamilton & Associates Securities Lawyers ()
www.securitieslawyer101.com

"In their SEC filings, in addition to the disclosures required by Regulation S-K and 20F, mining issuers must include the disclosures required by Industry Guide 7. All U.S mining companies that are SEC filers are required to report under its rules."

I have also submitted questions to the SEC's Corporate Finance Department to get their opinion on the issue. In the meantime, I'd like to know why you are so certain that what MDMN has done is "illegal"...meaning there is a law and they broke it, as opposed to merely doing something that could be deemed as improper. As I stated above, if you have verifiable factual evidence or legal precedence that Industry Guide 7 applies to MDMN or if you are an SEC attorney with experience in such matters, then I'm certainly willing to defer that you have a point. And as I said previously, I will notify the company immediately to correct any indiscretions on their part. However, thus far I've only heard the "Because-I-Said-So" argument from you which, no matter how emphatically you state it, is not factually supported.

Let me also state for the record, that I'm merely trying to find the answer to this issue. By trying to find the answer to this issue and pointing out that I've found no precedence for your opinion, I am in no way condoning the company including anything that could be potentially deceptive to its shareholders on its part. I personally believe that even if they are not required to follow the SEC's Industry Guide 7 as a non-filer, they should make the effort to do so.