SEC Comment Letter 0000000000-24-006078 to WisdomTree, Inc. (WT) (CIK 0000880631) (WT)
WisdomTree, Inc. (WT) (CIK 0000880631)
Date: May 24, 2024 · CIK: 0000880631 · Accession: 0000000000-24-006078
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-10932
Letter
United States securities and exchange commission logo May 24, 2024 Graham Tuckwell Founder and Executive Chairman ETFS Capital Limited 15 Rathbone Place London W1T 1HU United Kingdom Re:ETFS Capital Limited WisdomTree, Inc. DFAN filed May 21, 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. DFAN filed on May 21, 2024 Investor Presentation attached as Exhibit 1 1.We note your statement on slide 10 that "[a]ccording to publicly available information, WisdomTree has spent $10 million over the last two years by its own calculations on proxy fights.” Please supplementally provide more specific supporting data to allow stockholders to identify supporting source materials. In future soliciting materials, provide such support where these statements are made. 2.We note that slide 17 compares revenue and adjusted operating margin but does not disclose the applicable adjustments and includes "ETFS estimates" as a source for the information. Please clarify the adjustments made and, consistent with previous comments, ensure that you provide specific cites supporting disclosure of all figures and assertions of value.
FirstName LastNameGraham Tuckwell Comapany NameETFS Capital Limited May 24, 2024 Page 2 FirstName LastName Graham Tuckwell ETFS Capital Limited May 24, 2024 Page 2 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. Please direct any questions to Laura McKenzie at 202-551-4568 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
May 24, 2024
Graham Tuckwell
Founder and Executive Chairman
ETFS Capital Limited
15 Rathbone Place
London W1T 1HU
United Kingdom
Re:ETFS Capital Limited
WisdomTree, Inc.
DFAN filed May 21, 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.
DFAN filed on May 21, 2024
Investor Presentation attached as Exhibit 1
1.We note your statement on slide 10 that "[a]ccording to publicly available information,
WisdomTree has spent $10 million over the last two years by its own calculations on
proxy fights.” Please supplementally provide more specific supporting data to allow
stockholders to identify supporting source materials. In future soliciting materials, provide
such support where these statements are made.
2.We note that slide 17 compares revenue and adjusted operating margin but does not
disclose the applicable adjustments and includes "ETFS estimates" as a source for the
information. Please clarify the adjustments made and, consistent with previous
comments, ensure that you provide specific cites supporting disclosure of all figures and
assertions of value.
FirstName LastNameGraham Tuckwell
Comapany NameETFS Capital Limited
May 24, 2024 Page 2
FirstName LastName
Graham Tuckwell
ETFS Capital Limited
May 24, 2024
Page 2
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.
Please direct any questions to Laura McKenzie at 202-551-4568 or Christina Chalk at
(202) 551-3263.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions