0001489137-14-000070.txt : 20140627 0001489137-14-000070.hdr.sgml : 20140627 20140527163500 ACCESSION NUMBER: 0001489137-14-000070 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20140527 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Molycorp, Inc. CENTRAL INDEX KEY: 0001489137 STANDARD INDUSTRIAL CLASSIFICATION: METAL MINING [1000] IRS NUMBER: 272301797 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 5619 DENVER TECH CENTER PARKWAY STREET 2: SUITE 1000 CITY: GREENWOOD VILLAGE STATE: CO ZIP: 80111 BUSINESS PHONE: (303) 843-8040 MAIL ADDRESS: STREET 1: 5619 DENVER TECH CENTER PARKWAY STREET 2: SUITE 1000 CITY: GREENWOOD VILLAGE STATE: CO ZIP: 80111 CORRESP 1 filename1.htm SEC Comment Letter_May 22, 2014



May 27, 2014
CORRESPONDENCE FILING VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549    
Attention: Suying Li, Staff Accountant
    
Re:
Molycorp, Inc.
Item 4.01 Form 8-K Filed May 20, 2014
File No. 001-34827    
Ladies and Gentlemen:
Molycorp, Inc., a Delaware corporation (the “Company” or “we,” “us” or “our”), is submitting this letter in response to the comment letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), dated May 22, 2014 (the “Comment Letter”), with respect to the Company’s Current Report on Form 8-K filed May 20, 2014 (the “Form 8-K”).
Below is the Company’s response. For the convenience of the Staff, the Company has repeated the Staff’s comment before the corresponding response.

Form 8-K Filed May 20, 2014

1.
Comment: Your disclosure in the fourth paragraph under Item 4.01 pertains to circumstances during your interim period from January 1, 2014 through May 16, 2014. Please expand the disclosure to state whether, during your two most recent fiscal years and any subsequent interim period prior to the engagement of your new independent accountant, there were any consultations with your new independent accountant on any matter as described in Item 304(a)(2)(i) & (ii) of Regulation S-K.
Response: On May 27, 2014, we filed an amendment to the Form 8-K to include disclosure regarding the fiscal years ended December 31, 2012 and 2013 with respect to our new independent accountant.




United States Securities and Exchange Commission
Division of Corporation Finance
May 27, 2014
Page 2


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In connection with the above response, the Company acknowledges that:
•
the Company is responsible for the adequacy and accuracy of the disclosure in its filings;
•
Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; and
•
the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
If you have any questions regarding these matters, please do not hesitate to contact the undersigned at (303) 843-8040.


 
Very truly yours,
 
/s/ Kevin W. Johnson
 
Kevin W. Johnson
Executive Vice President and General Counsel