SEC Comment Letter for QUANTUM (QMCO) — Feb 22, 2017
QUANTUM CORP /DE/ (QMCO) (CIK 0000709283)
Date: Feb. 22, 2017 · CIK: 0000709283 · Accession: 0000000000-17-006006
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13449
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE February 21, 2017 By E-Mail Christopher P. Davis , Esq. Kleinberg, Kaplan, Wolff & Cohen, P.C. 551 Fifth Avenue, 18th Floor New York, NY 10176
Re: Quantum Corporation Revised Preliminary Proxy Statement filed February 17, 2017 Filed by VIEX Opportunities Fund, LP – Series One, et. al. File No. 001-13449
Dear Mr . Davis :
We have reviewed your filing and have the following commen ts.
Revised Preliminary Proxy Statement 1. We note your response to pri or comment 3 as it related to your statement that the board has disclosed “disparate information…to certain members of the Board, implying a ‘board -within -a-Board’ information structure.” Revise your disclosure to clarify that the basis for your disclosure are events that took place more than two years ago and were issues raised by another dissident security holder .
Reasons for the Solicitation 2. We reissue prior comment 4. Re vise your disclosure to clarify that you acceded to a request from the company to delay the annual meeting as part of broader agreement s between you and the company .
Please direct any questions to me at (202) 551 -3619.
Sincerely,
/s/ Daniel F. Duchovny
Daniel F. Duchovny
Special Counsel
Office of Mergers and Acquisitions
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
February 21, 2017
By E-Mail
Christopher P. Davis , Esq.
Kleinberg, Kaplan, Wolff & Cohen, P.C.
551 Fifth Avenue, 18th Floor
New York, NY 10176
Re: Quantum Corporation
Revised Preliminary Proxy Statement filed February 17, 2017
Filed by VIEX Opportunities Fund, LP – Series One, et. al.
File No. 001-13449
Dear Mr . Davis :
We have reviewed your filing and have the following commen ts.
Revised Preliminary Proxy Statement
1. We note your response to pri or comment 3 as it related to your statement that the board
has disclosed “disparate information…to certain members of the Board, implying a
‘board -within -a-Board’ information structure.” Revise your disclosure to clarify that the
basis for your disclosure are events that took place more than two years ago and were
issues raised by another dissident security holder .
Reasons for the Solicitation
2. We reissue prior comment 4. Re vise your disclosure to clarify that you acceded to a
request from the company to delay the annual meeting as part of broader agreement s
between you and the company .
Please direct any questions to me at (202) 551 -3619.
Sincerely,
/s/ Daniel F. Duchovny
Daniel F. Duchovny
Special Counsel
Office of Mergers and Acquisitions