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United States securities and exchange commission logo
March 31, 2023
Jeffrey E. Eberwein
Executive Chairman
Star Equity Holdings
53 Forest Ave., Suite 101
Old Greenwich, CT 06870
Re:Servotronics, Inc.
Preliminary Proxy Statement on Schedule 14A filed by Star Equity Holdings et
al.
Filed March 29, 2023
File No. 001-07109
Dear Jeffrey E. Eberwein:
            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 on Schedule 14A filed by Star Equity on March 29, 2023
Quorum; Broker Non-Votes; Discretionary Voting, page 22
1.We note the disclosure here and elsewhere that brokers will not have discretionary
authority to vote on any of the proposals.  It is our understanding that brokers may
exercise discretionary authority on routine matters if they do not receive soliciting
materials.  Please clarify throughout the filing or advise.
Other Matters and Additional Information, page 27
2.Please advise us when Star Equity anticipates distributing the proxy statement. Given that
reliance on Exchange Act Rule 14a-5(c) is impermissible at any time before the registrant
distributes its proxy statement, Star Equity will accept all legal risk in connection with
distributing the initial definitive proxy statement without all required disclosures and

 FirstName LastNameJeffrey E. Eberwein
 Comapany NameStar Equity Holdings
 March 31, 2023 Page 2
 FirstName LastName
Jeffrey E. Eberwein
Star Equity Holdings
March 31, 2023
Page 2
should undertake to subsequently provide any omitted information in a supplement in
order to mitigate that risk.
Proxy Card, page i
3.Please list the nominees in alphabetical order by last name for Company Nominees
Opposed by Star Equity.  See Rule 14a-19(e)(4).
4.We note the disclosure here and elsewhere that "if you mark more than six 'FOR' and/or
'WITHHOLD' boxes with respect to the election of directors, all of your votes for the
election of directors will be deemed invalid."  It is our understanding that a shareholder's
votes for the election of directors will be deemed invalid if a shareholder marks more than
six "FOR" boxes, as opposed to marking more than six "FOR" and/or "WITHHOLD"
boxes. Refer to the Company's proxy statement and card and revise or advise as
appropriate.
            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 at (202)
551-3444.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions