SEC Comment Letter 0000000000-24-005015 to WisdomTree, Inc. (WT) (CIK 0000880631) (WT)
WisdomTree, Inc. (WT) (CIK 0000880631)
Date: May 2, 2024 · CIK: 0000880631 · Accession: 0000000000-24-005015
AI Filing Summary & Sentiment
File numbers found in text: 001-10932
Letter
United States securities and exchange commission logo May 2, 2024 Graham Tuckwell Founder and Executive Chairman ETFS Capital Limited 15 Rathbone Place London W1T 1HU United Kingdom Re:ETFS Capital Limited WisdomTree, Inc. PRRN14A filed April 30, 2024 by ETFS Capital Limited and Graham Tuckwell File No. 001-10932 Dear Graham Tuckwell: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. PRRN14A filed April 30, 2024 Background to the Solicitation, page 6 1.We have reviewed your response to prior comment 3 and do not agree with your analysis or conclusion. We believe that the press release and letter to stockholders constituted a solicitation and should have been filed under cover of Schedule 14A. General 2.We have reviewed your response to prior comment 17. While we do not necessarily agree with your analysis or conclusion, we have no further comment at this time. 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 LastNameGraham Tuckwell Comapany NameETFS Capital Limited May 2, 2024 Page 2 FirstName LastName Graham Tuckwell ETFS Capital Limited May 2, 2024 Page 2 Please direct any questions to Laura McKenzie at 202-551-4568, Christina Chalk at 202- 551-3263, or David Plattner at 202-551-8094. Sincerely, Division of Corporation Finance Office of Mergers & Acquisitions
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United States securities and exchange commission logo
May 2, 2024
Graham Tuckwell
Founder and Executive Chairman
ETFS Capital Limited
15 Rathbone Place
London W1T 1HU
United Kingdom
Re:ETFS Capital Limited
WisdomTree, Inc.
PRRN14A filed April 30, 2024 by ETFS Capital Limited and Graham Tuckwell
File No. 001-10932
Dear Graham Tuckwell:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments by providing the requested information or advise us as
soon as possible when you will respond. If you do not believe our comments apply to your facts
and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
PRRN14A filed April 30, 2024
Background to the Solicitation, page 6
1.We have reviewed your response to prior comment 3 and do not agree with your analysis
or conclusion. We believe that the press release and letter to stockholders constituted a
solicitation and should have been filed under cover of Schedule 14A.
General
2.We have reviewed your response to prior comment 17. While we do not necessarily agree
with your analysis or conclusion, we have no further comment at this time.
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 LastNameGraham Tuckwell
Comapany NameETFS Capital Limited
May 2, 2024 Page 2
FirstName LastName
Graham Tuckwell
ETFS Capital Limited
May 2, 2024
Page 2
Please direct any questions to Laura McKenzie at 202-551-4568, Christina Chalk at 202-
551-3263, or David Plattner at 202-551-8094.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions