Meta Materials (MMATQ) CORRESP Correspondence with SEC

Property & Equipment Ceiling Test
12/31/2013
			TRLT TB
Evaluated OK properties			3,016,360		Ceiling Test
Evaluated TX properties			6,467,654
Non-Producing Leasehold Costs			4,758,805
Total			14,242,819		<A>	13,038,750	NBV
					SMOG.4	(12,060,015)	Tax basis
Accumulated Depletion			(1,204,069)			978,735	Book-Tax difference
Total			(1,204,069)			332,770	Related deferred income taxes using tax rate
					<D>	12,705,980	Net net book value after income tax effect
Net Assets			13,038,750	<A>
					<B>	26,524,574	PV Future Net Revenue-Discounted
	Reserve Report				SMOG.4	12,060,015	Tax basis
	Undiscounted		Discounted			14,464,559	Difference between PVFNR and tax basis
Future net revenue	53,560,159		26,524,574	<B>	<C>	4,917,950	Tax effected
Estimated tax basis	12,060,015	SMOG.4	12,060,015	SMOG.4
						Net, Net Book Value
Future net revenue (taxable)	41,500,144		14,464,559		<B>	26,524,574	PV Future Net Revenue-Discounted
					<C>	(4,917,950)	Income tax effect
Rate	34%		34%			21,606,624	Ceiling
					<D>	(12,705,980)	Net net book value
Deferred Taxes	14,110,049		4,917,950			8,900,644	Excess ceiling
Future net revenue after tax	27,390,095		9,546,609
Note 1:	This ceiling impairment test is performed based on guidelines of Regulation S-X, section 210.4-10, which relates to Oil and Gas Full Cost Accounting.
	Since there is an excess ceiling, no write-down of assets is necessary.  PFW.

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Torchlight Energy
Full Cost Ceiling Test
Year Ended December 31, 2012
	12/31/2012
Total Capitalized Costs	$	4,013,576
Less Accumulated DD&A		(551,890	)
Net Capitalized Costs		3,461,686
PV-10 Value of Proved Reserves		3,299,600		Per NSAI Reserve Report
Less Income Tax Effects (Discounted)		(391,000	)	From SMOG Calculation
Plus Unevaluated Costs		577,658		Primarily Coulter #1
Add Back Asset Retirement Obligation		11,521		To Prevent Double Counting
Full Cost Ceiling		3,497,779
Cushion / (Writedown Indicated)		36,093

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