SEC Comment Letter 0000000000-24-002395 to Macy's, Inc. (M) (CIK 0000794367) (M)
Macy's, Inc. (M) (CIK 0000794367)
Date: March 4, 2024 · CIK: 0000794367 · Accession: 0000000000-24-002395
AI Filing Summary & Sentiment
File numbers found in text: 001-13536
Letter
United States securities and exchange commission logo March 4, 2024 Gavriel Kahane Managing Partner Arkhouse Management Co. LP 106 W 56th Street, 17th Floor New York, NY 10019 Re:Arkhouse Management Co. LP Macy's, Inc. Soliciting Materials filed pursuant to Rule 14a-12 by Arkhouse Management Co. LP et al. Filed February 20, 2024 File No. 001-13536 Dear Gavriel Kahane: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Soliciting Materials filed pursuant to Rule 14a-12 Certain Information Concerning the Participants 1.In written soliciting materials used before a proxy statement is furnished, Rule 14a- 12(a)(1)(i) requires the soliciting party to include a description of each participant’s direct and indirect interests in the solicitation, or a legend advising where that information can be found. Such interests are not limited to the participant’s share ownership in the registrant. See the last sentence of CDI 132.03 under Proxy Rules and Schedules 14A/14C Compliance and Disclosure Interpretations (November 17, 2023). In future soliciting materials filed pursuant to Rule 14a-12, please include disclosure about the fact that Arkhouse Management recently made a proposal to acquire Macy’s, which was rejected. 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.
FirstName LastNameGavriel Kahane Comapany NameArkhouse Management Co. LP March 4, 2024 Page 2 FirstName LastName Gavriel Kahane Arkhouse Management Co. LP March 4, 2024 Page 2 Please direct any questions to Brian Soares at 202-551-3690 or Christina Chalk at 202- 551-3263. Sincerely, Division of Corporation Finance Office of Mergers & Acquisitions
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United States securities and exchange commission logo
March 4, 2024
Gavriel Kahane
Managing Partner
Arkhouse Management Co. LP
106 W 56th Street, 17th Floor
New York, NY 10019
Re:Arkhouse Management Co. LP
Macy's, Inc.
Soliciting Materials filed pursuant to Rule 14a-12 by Arkhouse Management
Co. LP et al.
Filed February 20, 2024
File No. 001-13536
Dear Gavriel Kahane:
We have reviewed your filing and have the following comment. In our comment, we may
ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment by providing the requested information or advise us as
soon as possible when you will respond. If you do not believe our comment applies to your facts
and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Soliciting Materials filed pursuant to Rule 14a-12
Certain Information Concerning the Participants
1.In written soliciting materials used before a proxy statement is furnished, Rule 14a-
12(a)(1)(i) requires the soliciting party to include a description of each participant’s direct
and indirect interests in the solicitation, or a legend advising where that information can
be found. Such interests are not limited to the participant’s share ownership in the
registrant. See the last sentence of CDI 132.03 under Proxy Rules and Schedules 14A/14C
Compliance and Disclosure Interpretations (November 17, 2023). In future soliciting
materials filed pursuant to Rule 14a-12, please include disclosure about the fact that
Arkhouse Management recently made a proposal to acquire Macy’s, which was rejected.
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.
FirstName LastNameGavriel Kahane
Comapany NameArkhouse Management Co. LP
March 4, 2024 Page 2
FirstName LastName
Gavriel Kahane
Arkhouse Management Co. LP
March 4, 2024
Page 2
Please direct any questions to Brian Soares at 202-551-3690 or Christina Chalk at 202-
551-3263.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions