United States securities and exchange commission logo
February 29, 2024
Pat Obara
Chief Financial Oficer
Uranium Energy Corp
500 North Shoreline, Ste. 800
Corpus Christi, Texas, USA
Re: Uranium Energy Corp
Form 10-K for the
Fiscal Year Ended July 1, 2023
Filed September 29,
2023
File No. 001-33706
Dear Pat Obara:
We have reviewed your
filing and have the following comments.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended July 1, 2023
Item 2. Description of Properties, page 28
1. It appears there are
inconsistencies between the notes to the summary resource table and
certain individual
property resource tables. For example, note 4 to Table 2.5 indicates a
long-term uranium price
of $40 per pound for ISR projects and $65 per pound for
conventional projects,
however Table 2.41 on page 87 discloses pricing of $56 per pound.
Additionally, note 5 to
Table 2.5 states that resources are 100% attributable to the
company, however Table
2.42 on page 93 states that the resources in the table are based
on UEC's 49.0975%
equity in the project.
We also note that you
have included two tables identified as Table 2.42, including Table
2.42 on page 93 and
Table 2.42 on page 90.
Please revise to ensure
the pricing and attributable resource disclosures are consistent
between individual
property resource tables and the summary resource table, and correct
the table numbers
listed with each table.
Pat Obara
Uranium Energy Corp
February 29, 2024
Page 2
2. We note that several of the properties that have been included in
Table 2.6, Year over
Year Changes in Mineral Resources, were acquired during the fiscal
year ending 2023,
however resource estimates related to these properties are reflected
in the fiscal year
ending 2022. Please revise as necessary.
3. As necessary please revise all individual property mineral resource
tables to include the
point of reference, the price, the cut-off grade, and the
metallurgical recovery factor as
required by Item 1304(d)(1) of Regulation S-K.
Item 15. Exhibits, Financial Statement Schedules
96.4, page 151
4. We note that you have assumed a cut-off grade of 0.05% U3O8 for your
Horseshoe-Raven
mineral resource, however you have not included underground mining
costs in the cut-off
grade calculation. Mining costs must be included in the cut-off
calculation in order to
establish a reasonable prospect of economic extraction; similar to
mining costs that were
included in the Roughrider Uranium technical report summary, provided
at Exhibit 96.10.
Please revise the technical report summary to include mining costs in
the cut-off grade
calculation, and revise the resource disclosure as necessary.
Please review your other technical report summaries to ensure that
mining costs have been
included in the cut-off grade, as necessary.
5. We note that disclosures under Reliance on Other Experts, on page 134
of the Technical
Report Summary, include categories of information beyond those that
are permissible
under Item 1302(f)(1) of Regulation S-K.
For example, in one paragraph of this section, the qualified person
indicates there has
been reliance with regard to content in Section 10, exclusively on
information and data
supplied by UEX.
Please discuss this observation with the qualified person and arrange
to obtain and file
a revised technical Report Summary that is consistent with the
requirements in Item
1302(f)(2) of Regulation S-K.
FirstName LastNamePat Obara
We generally anticipate that qualified persons would validate and
discuss information
Comapany NameUranium
utilized in preparingEnergy Corp
the report that is not within the categories
listed in the guidance
referenced above,
February 29, 2024 Page 2 in an alternate and corresponding section of the
report.
FirstName LastName
Pat Obara
FirstName LastNamePat
Uranium Energy Corp Obara
Comapany29,
February NameUranium
2024 Energy Corp
February
Page 3 29, 2024 Page 3
FirstName LastName
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Please contact John Coleman at 202-551-3610 or Craig Arakawa at
202-551-3650 if you
have questions regarding comments.
Sincerely,
Division of
Corporation Finance
Office of Energy &
Transportation