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 thefiling; | |
• | staff comments or changes to disclosure in response to staff comments do not foreclosethe 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 bythe 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 |