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SEC Comment Letter for PDL BIOPHARMA, INC. (CIK 0000882104) — Jul 2, 2020

PDL BIOPHARMA, INC. (CIK 0000882104)
Date: July 2, 2020 · CIK: 0000882104 · Accession: 0000000000-20-005964

AI Filing Summary & Sentiment

File numbers found in text: 000-19756

Date
July 2, 2020
Author
Not clearly detected
Form
UPLOAD
Company
PDL BIOPHARMA, INC. (CIK 0000882104)

Letter

United States securities and exchange commission logo July 2, 2020 Christopher Stone Vice President and General Counsel PDL BioPharma, Inc. 932 Southwood Boulevard Incline Village, Nevada 89451 Re:PDL BioPharma, Inc. Revised Preliminary Proxy Statement on Schedule 14A Filed June 30, 2020 File No. 000-19756 Dear Mr. Stone: We have reviewed your filing and have the following comment. 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Revised Preliminary Proxy Statement on Schedule 14A Background of the Proposed Dissolution and Plan of Dissolution, page 30 1.We note your response to prior comment 1. Please revise the Background section to indicate whether you have received any offers for the entire company to date, or advise. 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.

FirstName LastNameChristopher Stone Comapany NamePDL BioPharma, Inc. July 2, 2020 Page 2 FirstName LastName Christopher Stone PDL BioPharma, Inc. July 2, 2020 Page 2

Please contact Chris 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: Jacob D. Steele

Show Raw Text
United States securities and exchange commission logo
July 2, 2020
Christopher Stone
Vice President and General Counsel
PDL BioPharma, Inc.
932 Southwood Boulevard
Incline Village, Nevada 89451
Re:PDL BioPharma, Inc.
Revised Preliminary Proxy Statement on Schedule 14A
Filed June 30, 2020
File No. 000-19756
Dear Mr. Stone:
            We have reviewed your filing and have the following comment.
            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
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to the comment, we may have additional comments.
Revised Preliminary Proxy Statement on Schedule 14A
Background of the Proposed Dissolution and Plan of Dissolution, page 30
1.We note your response to prior comment 1.  Please revise the Background section to
indicate whether you have received any offers for the entire company to date, or advise.
            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.

 FirstName LastNameChristopher Stone
 Comapany NamePDL BioPharma, Inc.
 July 2, 2020 Page 2
 FirstName LastName
Christopher Stone
PDL BioPharma, Inc.
July 2, 2020
Page 2

            Please contact Chris 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:       Jacob D. Steele