United States securities and exchange commission logo
April 13, 2023
Gregory D. Swan
Chief Financial Officer
IperionX Limited
129 W Trade Street, Suite 1405
Charlotte, NC 28202
Re: IperionX Limited
Form 20-F for the
Fiscal Year ended June 30, 2022
Filed August 26,
2022
File No. 001-41338
Dear Gregory D. Swan:
We have reviewed your March 31, 2023 response to our comment
letter and have the
following comments. In some of our comments, we may ask you to provide
us with information
so we may better understand your disclosure.
Please respond to these comments by providing the requested
information or advise us as
soon as possible when you will respond. If you do not believe our
comments apply to your facts
and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have
additional comments.
Unless we note otherwise, our references to prior comments are to
comments in our March 20,
2023 letter.
Form 20-F for the Fiscal Year ended June 30, 2022
D. Property, Plant and Equipment
Titan Project, page 42
1. Please expand the
disclosures proposed in response to prior comment 3, regarding the
individual heavy
mineral prices, to also include the individual prices for all of the Rare
Earth Elements (REE)
that contribute to your REE concentrate price along with the
percentage of each REE
found in your typical concentrate sold.
Section 11.8 - Cut-off Grade, page E-28
2. We note your response
to prior comment 5 and the revisions proposed regarding
disclosure of
individual heavy mineral prices in the technical report summary. In addition
to those changes, the
individual prices for all of the Rare Earth Elements (REE) that
Gregory D. Swan
IperionX Limited
April 13, 2023
Page 2
contribute to the REE concentrate price along with the percentage of
each REE found in
your typical concentrate sold, should be disclosed; Table 21 should
also be modified to
include the historical prices along with the spot prices and forecast
prices utilized.
Section 13.3 - Production Target and Mine Schedule, page E-32
3. We note your response to prior comment 7 including the proposed final
mining limit map
and LOM mine production schedule. The technical report summary should
also include
the mining schedules utilized in the cash flow analyses for mining
both (i) indicated
resources and (ii) indicated resources with inferred resources.
Section 19 - Economic Analysis, page E-57
4. We note the revisions proposed in response to prior comment 10
regarding the cash flow
analyses for the indicated resources and combined indicated and
inferred resources.
The cash flow analyses should be further revised to include the
corresponding LOM
production schedule (tonnage & grade) and a line item for royalties;
and the results of the
analyses should be described in the accompanying text with equal
prominence.
You may contact George K. Schuler, Mining Engineer, at (202) 551-3718 if
you
have questions regarding the engineering comments or Karl Hiller, Branch Chief,
at (202) 551-
3686 with any other questions.
FirstName LastNameGregory D. Swan Sincerely,
Comapany NameIperionX Limited
Division of
Corporation Finance
April 13, 2023 Page 2 Office of Energy
& Transportation
FirstName LastName