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SEC Company Response from DIGIRAD CORP (STRR, STRRP) (CIK 0000707388) — Jan 12, 2022

DIGIRAD CORP (STRR, STRRP) (CIK 0000707388)
Date: Jan. 12, 2022 · CIK: 0000707388 · Accession: 0001193805-22-000042

AI Filing Summary & Sentiment

File numbers found in text: 333-261957

Date
January 12, 2022
Author
/s/ Spencer G. Feldman
Form
CORRESP
Company
DIGIRAD CORP (STRR, STRRP) (CIK 0000707388)

Letter

January 12, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn.: Jason L. Drory, Esq.

Division of Corporation Finance

Office of Life Sciences

Re: Star Equity Holdings, Inc. Registration Statement on Form S-1

Filed December 30, 2021

File No. 333-261957

Ladies and Gentlemen:

On behalf of Star Equity Holdings, Inc., a Delaware corporation (the “Company”), we are hereby filing in electronic format through EDGAR with the U.S. Securities and Exchange Commission, pursuant to the Securities Act of 1933, as amended, one complete copy of Amendment No. 1 to the captioned Registration Statement on Form S-1, for the registration of shares of the Company’s common stock (or pre-funded warrants in lieu of such shares) and warrants to purchase common stock, including one complete copy of the exhibits listed in Amendment No. 1 to the Registration Statement as filed therewith.

Amendment No. 1 to the Registration Statement reflects the preliminary number of shares of the Company’s common stock and warrants to be offered and related pricing information.

The Company expects that final pricing information will be provided in a final prospectus in reliance on Rule 430A. We expect to ask for acceleration of the effectiveness of the Registration Statement at the end of this week or beginning of next week. The request of Maxim Group will include the representation from the underwriters with respect to compliance with Rule 15c2-8. A copy of the letter from FINRA clearing the underwriting compensation arrangements for the offering will be forwarded to you immediately upon its receipt.

Should any member of the Commission’s staff have any questions concerning the enclosed materials or desire any further information or clarification in respect of Amendment No. 1 to the Registration Statement or the offering, please do not hesitate to contact me (tel.: (212) 451-2234) or Kenneth A. Schlesinger of our office (tel.: (212) 451-2252), or Jeffrey E. Eberwein, the Company’s Executive Chairman (tel.: (203) 489-9500).

Very truly yours,
/s/ Spencer G. Feldman

Show Raw Text
CORRESP
1
filename1.htm

January 12, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Attn.: Jason L. Drory, Esq.

  Division of Corporation Finance

  Office of Life Sciences

 Re: Star Equity Holdings, Inc.
 Registration Statement on Form S-1

                                                                   Filed December 30, 2021

                                                                   File No. 333-261957

Ladies and Gentlemen:

On behalf of Star Equity Holdings, Inc., a Delaware
corporation (the “Company”), we are hereby filing in electronic format through EDGAR with the U.S. Securities and Exchange
Commission, pursuant to the Securities Act of 1933, as amended, one complete copy of Amendment No. 1 to the captioned Registration Statement
on Form S-1, for the registration of shares of the Company’s common stock (or pre-funded warrants in lieu of such shares) and warrants
to purchase common stock, including one complete copy of the exhibits listed in Amendment No. 1 to the Registration Statement as filed
therewith.

Amendment No. 1 to the Registration Statement reflects
the preliminary number of shares of the Company’s common stock and warrants to be offered and related pricing information.

The Company expects that final pricing information
will be provided in a final prospectus in reliance on Rule 430A. We expect to ask for acceleration of the effectiveness of the Registration
Statement at the end of this week or beginning of next week. The request of Maxim Group will include the representation from the underwriters
with respect to compliance with Rule 15c2-8. A copy of the letter from FINRA clearing the underwriting compensation arrangements for the
offering will be forwarded to you immediately upon its receipt.

Should any member of the Commission’s staff
have any questions concerning the enclosed materials or desire any further information or clarification in respect of Amendment No. 1
to the Registration Statement or the offering, please do not hesitate to contact me (tel.: (212) 451-2234) or Kenneth A. Schlesinger of
our office (tel.: (212) 451-2252), or Jeffrey E. Eberwein, the Company’s Executive Chairman (tel.: (203) 489-9500).

  Very truly yours,

/s/ Spencer G. Feldman

Spencer G. Feldman

January 12, 2022

Page 2

Enclosures

 cc: Jason L. Drory, Esq.

                                                               Mr. Jeffrey E. Eberwein

                                                               Kenneth A. Schlesinger, Esq.

2