0001193125-13-448179.txt : 20140225 0001193125-13-448179.hdr.sgml : 20140225 20131120133100 ACCESSION NUMBER: 0001193125-13-448179 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20131120 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Hecla Alaska LLC CENTRAL INDEX KEY: 0001581090 IRS NUMBER: 203432198 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 BUSINESS PHONE: 2087694100 MAIL ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Hecla Admiralty Co CENTRAL INDEX KEY: 0001581155 IRS NUMBER: 261939060 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 BUSINESS PHONE: 2087694100 MAIL ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Hecla Juneau Mining Co CENTRAL INDEX KEY: 0001581159 IRS NUMBER: 521728103 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 BUSINESS PHONE: 2087694100 MAIL ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Hecla Ltd CENTRAL INDEX KEY: 0001581160 IRS NUMBER: 820126240 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 BUSINESS PHONE: 2087694100 MAIL ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Silver Hunter Mining Co CENTRAL INDEX KEY: 0001581171 IRS NUMBER: 262311170 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6500 N. MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 BUSINESS PHONE: 2087694100 MAIL ADDRESS: STREET 1: 6500 N. MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Hecla Silver Valley Inc CENTRAL INDEX KEY: 0001581208 IRS NUMBER: 208525633 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 BUSINESS PHONE: 2087694100 MAIL ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Hecla MC Subsidiary LLC CENTRAL INDEX KEY: 0001581210 IRS NUMBER: 300738758 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 BUSINESS PHONE: 2087694100 MAIL ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 FILER: COMPANY DATA: COMPANY CONFORMED NAME: RHL Holdings Inc CENTRAL INDEX KEY: 0001581170 IRS NUMBER: 450709033 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 BUSINESS PHONE: 2087694100 MAIL ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Burke Trading Inc CENTRAL INDEX KEY: 0001581149 IRS NUMBER: 201713481 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 BUSINESS PHONE: 208-769-4100 MAIL ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Rio Grande Silver Inc CENTRAL INDEX KEY: 0001581161 IRS NUMBER: 260715650 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 BUSINESS PHONE: 2087694100 MAIL ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 FILER: COMPANY DATA: COMPANY CONFORMED NAME: HECLA MINING CO/DE/ CENTRAL INDEX KEY: 0000719413 STANDARD INDUSTRIAL CLASSIFICATION: MINING, QUARRYING OF NONMETALLIC MINERALS (NO FUELS) [1400] IRS NUMBER: 770664171 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6500 N MINERAL DRIVE SUITE 200 STREET 2: NONE CITY: COEUR D'ALENE STATE: ID ZIP: 83815-9408 BUSINESS PHONE: 2087694100 MAIL ADDRESS: STREET 1: 6500 N MINERAL DRIVE SUITE 200 STREET 2: NONE CITY: COEUR D'ALENE STATE: ID ZIP: 83815-9408 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Hecla Greens Creek Mining Co CENTRAL INDEX KEY: 0001581176 IRS NUMBER: 841026255 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 BUSINESS PHONE: 2087694100 MAIL ADDRESS: STREET 1: 6500 N MINERAL DR STREET 2: SUITE 200 CITY: COEUR D ALENE STATE: ID ZIP: 83815 CORRESP 1 filename1.htm CORRESP

Hecla Mining Company

6500 North Mineral Drive, Suite 200

Coeur d’Alene, Idaho 83815

92080 769-4100

November 20, 2013

VIA EDGAR

Mr. John Reynolds

Assistant Director

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street NE

Washington, D.C. 20549

 

Re: Hecla Mining Company
     Registration Statement on Form S-4
     Filed October 28, 2013
     Amendment No. 1 to Registration Statement on Form S-4
     Filed November 20, 2013
     File Nos. 333-191935 and 333-191935-01 to 333-191935-11

Dear Mr. Reynolds:

This letter supplements the Registration Statement on Form S-4 (File Nos. 333-191935 and 333-191935-01 to 333-191935-11) of Hecla Mining Company (the “Company”) and its guarantor subsidiaries (each an additional registrant and, collectively with the Company, the “Registrants”) with respect to an offer to exchange (the “Exchange Offer”), for the Company’s 6.875% Senior Notes due 2021 (the “Outstanding Notes”), which were originally issued on April 12, 2013 to qualified institutional buyers and non-U.S. persons pursuant to Rule 144A and Regulation S under the Securities Act of 1933, as amended (the “Securities Act”), new notes with terms materially identical to the Outstanding Notes but which have been registered under the Securities Act (the “Exchange Notes”), and, therefore, will not be subject to the transfer restrictions applicable to the Outstanding Notes. In connection with the above-referenced Registration Statement on Form S-4 (the “Registration Statement”), the Registrants hereby confirm and represent as follows:

1.         The Registrants are registering the Exchange Offer in reliance on the position and representations of the staff of the Securities and Exchange Commission (the “Staff”) set forth in Shearman & Sterling, SEC No-Action Letter (available July 2, 1993), Morgan Stanley & Co., Inc., SEC No-Action Letter (available June 5, 1991), and Exxon Capital Holding Corp., SEC No-Action Letter (available May 13, 1988) (together, the “No Action Letters”).

2.         The Registrants have not entered into any arrangement or understanding with any person to distribute the Exchange Notes to be received in the Exchange Offer and, to the best of the Registrants’ knowledge and belief, each person participating in the Exchange Offer is acquiring the Exchange Notes in its ordinary course of business and has no arrangement or understanding with any person to participate in the distribution of the Exchange Notes to be received in the Exchange Offer. In this regard, the Registrants will make each person participating in the Exchange Offer aware (through the prospectus or the letter of transmittal) that, if such person is tendering Outstanding Notes in the Exchange Offer with the intention of participating in any manner in a distribution of the Exchange Notes, such person (i) cannot rely on the Staff’s position enunciated in the No Action Letters or interpretative letters to similar effect and (ii) must comply with the registration and prospectus delivery requirements of the Securities Act, in connection with a secondary resale transaction. The Registrants acknowledge that such a secondary resale transaction by such person participating in the Exchange Offer for the purpose of distributing the Exchange Notes should be covered by an effective registration statement containing the selling security holder information required by Item 507 or Item 508, as applicable, of Regulation S-K.

3.         The Registrants will make each person participating in the Exchange Offer aware (through the prospectus or the letter of transmittal) that any broker-dealer that will receive Exchange Notes for its own account in exchange for Outstanding Notes that were acquired as a result of market-making activities or other trading activities may be a statutory underwriter and must deliver a prospectus meeting the requirements of the Securities Act in connection with any resale of such Exchange Notes.

4.         None of the Registrants nor any of their respective affiliates have entered into any arrangement or understanding with any broker-dealer to distribute the Exchange Notes.

5.         The Registrants will include in the letter of transmittal to be executed by an exchange offeree in order to participate in the Exchange Offer a provision to the effect that if the exchange offeree is a broker-dealer holding Outstanding Notes acquired for its own account as a result of market-making activities or other trading activities, such broker-dealer will acknowledge that it will deliver a prospectus meeting the requirements of the Securities Act in connection with any resale of Exchange Notes received in respect of such Outstanding Notes pursuant to the Exchange Offer. The letter of transmittal also will include a statement to the effect that by so acknowledging and by delivering a prospectus, a broker-dealer will not be deemed to admit that it is an “underwriter” within the meaning of the Securities Act.

If any additional supplemental information is required by the Staff, please contact the undersigned at (208) 769-4100 or J. Craig Walker of K&L Gates LLP at (312) 807-4321.

 

Very truly yours,

 

HECLA MINING COMPANY

By:   /s/ David C. Sienko
Name: David C. Sienko
Title: General Counsel