We understand that some investors have attempted to discredit our research, observing differences between the mining permit number/address on the official Ping Ying Mine chopped business license and Mining Permit compared to web sites posting disclosing the sale of the Ping Yi Mine. Conclusions based on this observation are baseless.
The Mining Permit number issue in no way unsubstantiates our findings. Our research is based on a mountain of findings.
- Our research was performed using the official Business License and Mining Permit posted by the owner. Website postings are secondary to our conclusions, except for the sale information itself.
- We have obtained an official chopped SAIC filing of the Ping Yi Mine that clearly shows that LLEN does not own this mine.
- Most importantly, the press release issued by LLEN on Jan 17, 2012 states that, "Regarding the sale notices mentioned by GeoInvesting in its article, the Company never authorized or prepared such sale notices. Accordingly, the Company does not know the source of such notices." In other words, it does not dispute that the Ping Yi Mine is for sale.
- The only issue regarding the difference in addresses is that the owner refers to the older address of Ping Yi Mine (we will address below).
- We note that outside of a possible typo or human error regarding the Mining Permit number, there are no discrepancies in our argument about the ownership of Ping Yi Mine.
We stand by our conclusion that LLEN does not and never did own the Ping Yi Mine. Investors who do not embrace this conclusion are grasping for strings and playing a dangerous game.
For more detail on the mining permit and issue about the address, please read the following explanation:
In this detailed sales post, the sale representative posted the map of Ping Yi Mine, the business license of Ping Yi Mine and the Mining Permit of the Ping Yi Mine (http://www.worldmr.net/Exhibition/ForeCastList/Info/2011-10-11/112458.shtml). The Mining Permit is as follows:
The first paragraph of the introduction of the Ping Yi Mine in the same sales post states:
"平关平迤煤矿位于盘县平关镇三道沟境内，距平关约10Km ，有简易的公路相通，距红果镇约25 Km，交通较为方便。根据贵州省国土资源厅颁布发的采矿许可证（证号：5200000711358）划定的矿界，采矿权范围由8个拐点圈定，矿区面积为2.2694平方公里，开采标高2250m-2100m。"
Translated into English:
"Pingguan Ping yi Mine locates at Sandaogou, Pinguan town, Pan County. It is around 10 km away from Pingguan and there is a low level paved road links Pingguan to the Mine. It is around 25 km away from Hongguo twon and the transportation is very convenient. Based on the mine map in the mining permit issued by Natural Resource Bureau of Guizhou province (No. 5200000711358), eight coordinates defines the scale of the mine with the 2.2694 m2 and the exploration depth is 2250-2210 m."
Apparently, there are two discrepancies between the web sales posting of the Ping Yi Mine and the posted business license and mining permit of Ping Yi Mine.
"Sandaogou Pingguan Town" vs. "Yiche village, Pingguan Town" in the Business License
|"No. 5200000711358" vs.|
In the SAIC file, there is a corporate change page as follows:
This corporate change clearly explained that the Ping Yi Mine moved from Sandaogou to the current address, Yiche village. It is reasonable to believe that when the owners wrote the sale posting, they made a mistake and used the old address on the sale post.
When the owners wrote the sale posting, they used the Mining Permit number "No. 5200000711358", rather than the , which Ping Yi Mine obtained on Aug. 2008 and is disclosed in the official mining permit in the same sale posting. There are several reasons for this mistake:
- A typo
- Before Aug. 2008, Ping Yi Mine had another Mining Permit, which may have carried the number "No. 5200000711358".
This does not debunk our finding that LLEN does not own Ping Yi Mine, which is clearly shown in the SAIC file.