SEC Company Response from BROOKSTONE INC (CIK 0000830134) — Aug 22, 2005
BROOKSTONE INC (CIK 0000830134)
Date: Aug. 22, 2005 · CIK: 0000830134 · Accession: 0001193125-05-172625
AI Filing Summary & Sentiment
Letter
VIA EDGAR AND FACSIMILIE Securities and Exchange Commission Division of Corporation Finance Washington, D.C. 20549 Attn: Mr. Matthew Benson Re: Brookstone, Inc.—Schedule 14A and Schedule 13E-3 (File No. 0-21406)
Dear Mr. Benson:
We represent Brookstone, Inc. (the “Company”) in connection with the Preliminary Schedule 14A and Schedule 13E-3 (File No. 0-21406) (the “Filing”) previously filed with the Securities and Exchange Commission (the “Commission”), which has been the subject of review and comment by the staff of the Commission (the “Staff”).
In connection with the filing of a definitive Schedule 14A today by the Company, on behalf of our client, the Company acknowledges that it is the view of the Securities and Exchange Commission (the “Commission”) that (i) comments by the Commission or the Staff on changes to disclosure in response to Staff comments does not foreclose the Commission from taking any action with respect to the filing, (ii) the action of the Commission or the Staff does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing, and (iii) the Company may not assert Commission or Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Thank you for your assistance.
Very truly yours,
/s/ David B. Walek
David B. Walek
KAYE SCHOLER LLP
Stephen C. Koval
212 836-8019
Fax 212 836-6419
skoval@kayescholer.com
425 Park Avenue
New York, New York 10022-3598
212 836-8000
Fax 212 836-8689
www.kayescholer.com
August 22, 2005
VIA EDGAR AND FACSIMILIE
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Mr. Matthew Benson
Re:
Brookstone, Inc.—Schedule 14A and Schedule 13E-3 (File No. 0-21406)
Dear Mr. Benson:
We represent Brookstone Holdings Corp., Brookstone Acquisition Corp., OSIM Brookstone Holdings, L.P., OSIM Brookstone Holdings, Inc., J.W. Childs Equity Partners III, L.P., J.W. Childs Advisors III, L.P., J.W. Childs Associates, L.P., OSIM International Ltd, Century Private Equity Holdings (S) Pte Ltd, Seletar Investments Pte Ltd and Temasek Capital (Private) Limited (collectively, the “Investor Group”) in connection with the Preliminary Schedule 14A and Schedule 13E-3 (File No. 0-21406) previously filed with the Securities and Exchange Commission (the “Commission”), which has been the subject of review and comment by the staff of the Commission (the “Staff”).
In connection with the filing of a definitive Schedule 14A today by Brookstone, Inc. and the filing of an amendment to the Schedule 13E-3 today by the Investor Group and others, on behalf of our clients, we acknowledge that it is the view of the Commission that (i) comments by the Commission or the Staff on changes to disclosure in response to Staff comments does not foreclose the Commission from taking any action with respect to the filings, (ii) the action of the Commission or the Staff does not relieve the Investor Group from its full responsibility for the adequacy and accuracy of the disclosure in the filings, and (iii) the Investor Group may not assert Commission or Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Thank you for your assistance.
Very truly yours,
/s/ Stephen C. Koval
Stephen C. Koval
August 22, 2005
VIA EDGAR AND FACSIMILIE
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Mr. Matthew Benson
Re:
Brookstone, Inc.—Schedule 14A and Schedule 13E-3 (File No. 0-21406)
Dear Mr. Benson:
We are Filing Persons in connection with the Preliminary Schedule 14A and Schedule 13E-3 (File No. 0-21406) (the “Filing”) of Brookstone, Inc. (the “Company”) previously filed with the Securities and Exchange Commission (the “Commission”), which has been the subject of review and comment by the staff of the Commission (the “Staff”).
In connection with the filing of a definitive Schedule 14A today by the Company, we acknowledges that it is the view of the Securities and Exchange Commission (the “Commission”) that (i) comments by the Commission or the Staff on changes to disclosure in response to Staff comments does not foreclose the Commission from taking any action with respect to the filing, (ii) the action of the Commission or the Staff does not relieve from our full responsibility for the adequacy and accuracy of the disclosure in the filing, and (iii) we may not assert Commission or Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
/s/ Michael Anthony
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SEC LETTER
ROPES
& GRAY
ROPES & GRAY LLP
ONE INTERNATIONAL PLACE
BOSTON, MA 02110-2624
617-951-7000
F 617-951-7050
BOSTON
NEW YORK
PALO ALTO
SAN FRANCISCO
WASHINGTON, DC
www.ropesgray.com
August 22, 2005
David B. Walek
(617) 951-7388
david.walek@ropesgray.com
VIA EDGAR AND FACSIMILIE
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn:
Mr. Matthew Benson
Re:
Brookstone, Inc.—Schedule 14A and Schedule 13E-3 (File No. 0-21406)
Dear Mr. Benson:
We represent Brookstone, Inc. (the “Company”) in connection with the Preliminary Schedule 14A and Schedule 13E-3 (File No. 0-21406) (the “Filing”)
previously filed with the Securities and Exchange Commission (the “Commission”), which has been the subject of review and comment by the staff of the Commission (the “Staff”).
In connection with the filing of a definitive Schedule 14A today by the Company, on behalf of
our client, the Company acknowledges that it is the view of the Securities and Exchange Commission (the “Commission”) that (i) comments by the Commission or the Staff on changes to disclosure in response to Staff comments does not
foreclose the Commission from taking any action with respect to the filing, (ii) the action of the Commission or the Staff does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing,
and (iii) the Company may not assert Commission or Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Thank you for your assistance.
Very truly yours,
/s/ David B. Walek
David B. Walek
KAYE SCHOLER LLP
Stephen C. Koval
212 836-8019
Fax 212 836-6419
skoval@kayescholer.com
425 Park Avenue
New York, New York 10022-3598
212 836-8000
Fax 212 836-8689
www.kayescholer.com
August 22, 2005
VIA EDGAR AND FACSIMILIE
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Mr. Matthew Benson
Re:
Brookstone, Inc.—Schedule 14A and Schedule 13E-3 (File No. 0-21406)
Dear Mr. Benson:
We represent Brookstone Holdings Corp., Brookstone Acquisition Corp., OSIM Brookstone Holdings, L.P., OSIM Brookstone Holdings, Inc., J.W. Childs Equity Partners III,
L.P., J.W. Childs Advisors III, L.P., J.W. Childs Associates, L.P., OSIM International Ltd, Century Private Equity Holdings (S) Pte Ltd, Seletar Investments Pte Ltd and Temasek Capital (Private) Limited (collectively, the “Investor
Group”) in connection with the Preliminary Schedule 14A and Schedule 13E-3 (File No. 0-21406) previously filed with the Securities and Exchange Commission (the “Commission”), which has been the subject of review and comment by the
staff of the Commission (the “Staff”).
In connection with the filing
of a definitive Schedule 14A today by Brookstone, Inc. and the filing of an amendment to the Schedule 13E-3 today by the Investor Group and others, on behalf of our clients, we acknowledge that it is the view of the Commission that (i) comments
by the Commission or the Staff on changes to disclosure in response to Staff comments does not foreclose the Commission from taking any action with respect to the filings, (ii) the action of the Commission or the Staff does not relieve the
Investor Group from its full responsibility for the adequacy and accuracy of the disclosure in the filings, and (iii) the Investor Group may not assert Commission or Staff comments as a defense in any proceeding initiated by the Commission or
any person under the federal securities laws of the United States. Thank you for your assistance.
Very truly yours,
/s/ Stephen C. Koval
Stephen C. Koval
August 22, 2005
VIA EDGAR AND FACSIMILIE
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Mr. Matthew Benson
Re:
Brookstone, Inc.—Schedule 14A and Schedule 13E-3 (File No. 0-21406)
Dear Mr. Benson:
We are Filing Persons in connection with the Preliminary Schedule 14A and Schedule 13E-3 (File No. 0-21406) (the “Filing”) of Brookstone, Inc. (the
“Company”) previously filed with the Securities and Exchange Commission (the “Commission”), which has been the subject of review and comment by the staff of the Commission (the “Staff”).
In connection with the filing of a definitive Schedule 14A today by the Company, we
acknowledges that it is the view of the Securities and Exchange Commission (the “Commission”) that (i) comments by the Commission or the Staff on changes to disclosure in response to Staff comments does not foreclose the Commission
from taking any action with respect to the filing, (ii) the action of the Commission or the Staff does not relieve from our full responsibility for the adequacy and accuracy of the disclosure in the filing, and (iii) we may not assert
Commission or Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
/s/ Michael Anthony
Michael Anthony
/s/ Philip Roizin
Philip Roizin