SEC Company Response from DIGIRAD CORP (STRR, STRRP) (CIK 0000707388) — Jan 18, 2022
DIGIRAD CORP (STRR, STRRP) (CIK 0000707388)
Date: Jan. 18, 2022 · CIK: 0000707388 · Accession: 0001193805-22-000075
AI Filing Summary & Sentiment
File numbers found in text: 333-261957
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CORRESP
1
filename1.htm
January 18, 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.
Amendment No. 2 to Registration Statement on Form S-1
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. 2 to the 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. 2 to the Registration Statement as filed
therewith.
Amendment No. 2 to the Registration Statement primarily
reflects an increase in the number of common stock purchase warrants being offered by the Company from 3,333,334 to 6,666,668 shares (excluding
warrants subject to the underwriters’ over-allotment option), or, in other words, one full warrant for every share of common stock
offered.
As we have previously advised the staff, the underwriters
and the Company expect to price the offering on Wednesday, January 19, 2022, and expect to file requests with the staff for acceleration
of effectiveness of the Registration Statement to 4:30 p.m. on January 19, 2022, or as soon thereafter as practicable. 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 18, 2022
Page 2
Enclosures
cc: Jason L. Drory, Esq.
Mr. Jeffrey E. Eberwein
Kenneth A. Schlesinger, Esq.