Alexandra Capital Corp. - SEC Correspondence

0001062993-15-006656.txt : 20160120 0001062993-15-006656.hdr.sgml : 20160120 20151214150722 ACCESSION NUMBER: 0001062993-15-006656 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20151214 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ALEXANDRA CAPITAL CORP. CENTRAL INDEX KEY: 0001639142 STANDARD INDUSTRIAL CLASSIFICATION: GOLD & SILVER ORES [1040] IRS NUMBER: 000000000 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 2075 WEST 37TH AVENUE CITY: VANCOUVER STATE: A1 ZIP: V6M 1N7 BUSINESS PHONE: (604) 687-6991 MAIL ADDRESS: STREET 1: 2075 WEST 37TH AVENUE CITY: VANCOUVER STATE: A1 ZIP: V6M 1N7 CORRESP 1 filename1.htm Alexandra Capital Corp. - SEC Correspondence - Filed by newsfilecorp.com

Alexandra Capital Corp.
300 - 2015 Burrard Street
Vancouver, British Columbia
Canada V6J 3H3

December 14, 2015

VIA EDGAR

Securities and Exchange Commission
100 F. Street, NE
Washington, D.C. 20549-7410

Attention:	John Reynolds,
	Assistant Director

Dear Sirs:

	Re:	Alexandra Capital Corp. (the “Company”)
		Amendment No. 3 to Form 20-FR (12g)
		Filed December 8, 2015
		File No. 000-55509

We write in response to your letter of December 11, 2015 regarding the above referenced amended registration statement on Form 20 FR(12g). Concurrently with this response we have filed a fourth amendment to the registration statement addressing your comments. For your ease of reference, our responses to your comments are numbered below in a corresponding manner:

Item 18. Financial Statements, page 54

1. Please include the audited financial statements for the years ended November 30, 2013 and 2012 under this heading.

Response: We have included the financial statements for the years ended November 30, 2013 and 2012 under Item 18 of our amended Form 20-F.

Financial Statements for the Fiscal Years Ended November 30, 2013 and 2012

Independent Auditors’ Report, page 101

2. Please refer to Item 17(c) of Form 20-F and AU 341.13 and amend your filing to provide a revised independent auditor’s report that:

	•	indicates management’s responsibility that the financial statements are in accordance with IFRS as issued by the IASB;

	•	indicates that the audit was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States); and

	•	includes an opinion on whether the financial statements comply with IFRS as issued by the IASB.

Response: We have included an audit report as requested under Item 18 of our amended Form 20-F.

We trust the foregoing is in order, however please contact the undersigned should you required additional information. The Company acknowledges that:

	•	the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

	•	staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; 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.

Yours truly,

ALEXDANRA CAPITAL CORP.

	Per:	/s/Blake Olafson
		Mr. Blake Olafson
		Chief Executive Officer