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sanbrunobaby

07/17/13 4:40 PM

#65428 RE: ficose #65414

somehow you are responding to me when it was someone else who posted the excerpts from SEC comment letters.

i did specifically post guideline comments from Ontario securities Commission previously for example, which specifically identified as a "red flag" companies which reported metal values in the ground without extraction costs.and SEC guide 7 pretty easy to look up.

it is hard for me to read SEC Guide 7, then this company filings and come back with impression they are complying with the guidelines.it is equally hard to read NI43-101 requirements and come away with feeling that this company has overall complied with the spirit and letter of the criteria required.and it is deifnitely misleading in my opinion their use of NI43-101 references : lee rice is an american and member of SME, company is USA company, why not prepare techncial report according to american standards ?

ye sthey have covered themselves with a lot of qualifiers, but the SEC when they get to a comment letter on such things wont fool around with a company claiming values based on gross value of metal without extraction costs.