SEC Comment Letter for PDL BIOPHARMA, INC. (CIK 0000882104) — Jun 19, 2020
PDL BIOPHARMA, INC. (CIK 0000882104)
Date: June 19, 2020 · CIK: 0000882104 · Accession: 0000000000-20-005482
AI Filing Summary & Sentiment
File numbers found in text: 000-19756
Letter
United States securities and exchange commission logo June 18, 2020 Christopher Stone Vice President and General Counsel PDL BioPharma, Inc. 932 Southwood Boulevard Incline Village, Nevada 89451 Re:PDL BioPharma, Inc. Amendment No. 1 to Preliminary Proxy Statement on Schedule 14A Filed June 5, 2020 File No. 000-19756 Dear Mr. Stone: 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 within ten business days 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. Amendment No. 1 to Preliminary Proxy Statement Background of the Proposed Dissolution and Plan of Dissolution, page 30 1.We note that your response to prior comment 2 addresses potential competitive disadvantage but does not address whether disclosure concerning offers, indications of interest, and negotiations are required or material to the voting decision. Please provide us with an analysis or revise to disclose this information. General 2.We note your response to prior comment 5. Please revise page 41 to disclose, if true, that you would file a Schedule 13E-3 in the event that your plans change and you sell to affiliates, or advise.
FirstName LastNameChristopher Stone Comapany NamePDL BioPharma, Inc. June 18, 2020 Page 2 FirstName LastName Christopher Stone PDL BioPharma, Inc. June 18, 2020 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Christopher Edwards at (202) 551-6761 or Joe McCann at (202) 551- 6262 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Nathan Kryszak
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United States securities and exchange commission logo
June 18, 2020
Christopher Stone
Vice President and General Counsel
PDL BioPharma, Inc.
932 Southwood Boulevard
Incline Village, Nevada 89451
Re:PDL BioPharma, Inc.
Amendment No. 1 to Preliminary Proxy Statement on Schedule 14A
Filed June 5, 2020
File No. 000-19756
Dear Mr. Stone:
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 within ten business days 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.
Amendment No. 1 to Preliminary Proxy Statement
Background of the Proposed Dissolution and Plan of Dissolution, page 30
1.We note that your response to prior comment 2 addresses potential competitive
disadvantage but does not address whether disclosure concerning offers, indications of
interest, and negotiations are required or material to the voting decision. Please provide
us with an analysis or revise to disclose this information.
General
2.We note your response to prior comment 5. Please revise page 41 to disclose, if true, that
you would file a Schedule 13E-3 in the event that your plans change and you sell to
affiliates, or advise.
FirstName LastNameChristopher Stone
Comapany NamePDL BioPharma, Inc.
June 18, 2020 Page 2
FirstName LastName
Christopher Stone
PDL BioPharma, Inc.
June 18, 2020
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Please contact Christopher Edwards at (202) 551-6761 or Joe McCann at (202) 551-
6262 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Nathan Kryszak