October 24, 2017
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street, NE
Washington, DC 20549
Attention: John Reynolds, Assistant Director Dear Sirs:
| Re: | Scandium International Mining Corp. |
| Form 10-K for the Year Ended December 31, 2016 | |
| File No. 000-54416 |
This letter is in response to the SEC comment letter dated October 17, 2017. We advise as follows in response to the comments set forth in the letter:
Form 10-K for the Fiscal Year Ended December 31, 2017
Item 2. Properties page 26
| 1. | We have forwarded a CD containing the independent marketing report regarding Scandium supply and demand outlook to your engineer as supplemental information. |
| 2. | In regards to page 31 regarding the offtake agreement with ALCERECO, we advise that the offtake contract does not include a take-or-pay provision. To the extent that the offtake agreement with ALCERECO is discussed and included in future filings, we will include a statement as follows: “The offtake agreement does not provide for a mandatory annual minimum purchase volume of scandium oxide by ALCERECO, and there is no requirement for payment in lieu of purchase.” |
We trust the foregoing is satisfactory.
Yours truly,
SCANDIUM INTERNATIONAL MINING CORP.
| Per: | /s/ George Putnam | |
| George Putnam, CEO |
Letter to SEC Oct 24