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B402

03/16/13 7:48 PM

#13713 RE: B402 #13705

We note that you disclose mineral resources and estimates of quantities of mineralized materials throughout your filing. The provisions in paragraph (b)(5)(3) of Industry Guide 7 generally limit the disclosure of mineralization to proven or probable reserves in filings with the United States Securities and Exchange Commission. Please revise to remove all resource disclosure and estimates of quantities of mineralized materials that do not meet the definition of a proven or probable reserve as defined in paragraph (a) of Industry Guide 7.

http://www.sec.gov/Archives/edgar/data/1412126/000000000012049259/filename1.pdf



3. We note your response to comment 6 from our letter dated September 10th, 2012. For each of your properties please provide a clear statement that the property is without mineral reserves, pursuant to paragraph (b)(4)(i) of Industry Guide 7.

4. We note your response to comment 7 from our letter dated September 10th, 2012. It appears your amended disclosure contains indicated resources, inferred resources, and stockpile and/or tailings estimates with historical sampling data. Please revise to remove all estimates of mineralization until you have defined a proven or probable reserve pursuant to paragraph (b)(5)(3) of Industry Guide 7.

http://www.sec.gov/Archives/edgar/data/1412126/000000000012056203/filename1.pdf