SEC Comment Letter 0000000000-23-003236 to SERVOTRONICS INC /DE/ (CIK 0000089140)
SERVOTRONICS INC /DE/ (CIK 0000089140)
Date: March 30, 2023 · CIK: 0000089140 · Accession: 0000000000-23-003236
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File numbers found in text: 001-07109
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United States securities and exchange commission logo
March 30, 2023
William F. Farrell, Jr.
Chief Executive Officer
Servotronics, Inc.
1110 Maple St.
Elma Center, NY 14059
Re:Servotronics, Inc.
Preliminary Proxy Statement on Schedule 14A
Filed March 24, 2023
File No. 001-07109
Dear William F. Farrell, Jr.:
We have reviewed your filing 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.
Preliminary Proxy Statement on Schedule 14A filed March 24, 2023
General
1.Please disclose the total amount estimated to be spent and total expenditures to date. See
Item 4(b) of Schedule 14A.
2.Please provide the required Item 407(d)(3) of Regulation S-K. See Item 7(b) of Schedule
14A.
3.Please provide the information required by Item 23 of Schedule 14A.
How many shares must be present to hold the Annual Meeting?, page 5
4.We note the disclosure here and elsewhere that brokers will not have discretionary
authority to vote on routine matters. It is our understanding that brokers may exercise
discretionary authority on routine matters if they do not receive soliciting materials from
the dissident. Please clarify throughout the filing.
FirstName LastNameWilliam F. Farrell, Jr.
Comapany NameServotronics, Inc.
March 30, 2023 Page 2
FirstName LastName
William F. Farrell, Jr.
Servotronics, Inc.
March 30, 2023
Page 2
How many votes are needed for approval of each proposal?, page 5
5.We note the disclosure here that a broker non-vote "will not affect" the outcome or
election. However, in the preceding paragraph you state that you do not expect to have
any broker-non votes at the Annual meeting. Please clarify.
Proxy Card, page i
6.Please include the names of the Star Equity nominees on the proxy card. See Rule 14a-
19(e)(1).
We remind you that the filing persons are responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please direct any questions to Michael Killoy at (202) 551-7576 or Perry Hindin (202)
551-3444.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions