SEC Company Response from PDL BIOPHARMA, INC. (CIK 0000882104) — Jul 2, 2020
PDL BIOPHARMA, INC. (CIK 0000882104)
Date: July 2, 2020 · CIK: 0000882104 · Accession: 0000882104-20-000098
AI Filing Summary & Sentiment
File numbers found in text: 000-19756
Referenced dates: July 2, 2020
Letter
Document
12670 High Bluff Drive
San Diego, California 92130
Tel: +1.858.523.5400 Fax: +1.858.523.5450
www.lw.com
FIRM / AFFILIATE OFFICES
Beijing
Moscow
Boston
Munich
Brussels
New York
Century City
Orange County
Chicago
Paris
Dubai
Riyadh
Düsseldorf
San Diego
Frankfurt
San Francisco
Hamburg
Seoul
Hong Kong
Shanghai
Houston
Silicon Valley
London
Singapore
Los Angeles
Tokyo
Madrid
Washington, D.C.
Milan
July 2, 2020
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Life Sciences
100 F Street N.E.
Washington, D.C. 20549
Attn: Chris Edwards
Re:
PDL BioPharma, Inc.
Revised Preliminary Proxy Statement on Schedule 14A
Filed on June 30, 2020
File No. 000-19756
Ladies and Gentlemen:
We are in receipt of the letter from the staff of the Securities and Exchange Commission (the “Staff”) dated July 2, 2020 (the “Third Letter”) with respect to the above-referenced Revised Preliminary Proxy Statement (the “Revised Preliminary Proxy Statement”). We are responding to the Staff’s comments on behalf of PDL BioPharma, Inc. (the “Company”) as set forth below.
The Company’s response set forth in this letter is numbered to correspond to the comment in the Third Letter. All terms used but not defined herein have the meanings assigned to such terms in the Revised Preliminary Proxy Statement. For ease of reference, we have set forth the Staff’s comment and the Company’s response below.
Revised Preliminary Proxy Statement on Schedule 14A, filed on June 30, 2020
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.
Company’s Response: The Company will revise the disclosure in the “Background of the Proposed Dissolution and Plan of Dissolution” section in response to the Staff’s comment by adding the following sentence to the Company’s definitive proxy statement: “As of the date of this proxy statement, we have not received any offer to purchase the entire company.”
Please do not hesitate to contact me at (858) 523-3950 with any questions or comments regarding this correspondence. Thank you in advance for your cooperation in connection with this matter.
Sincerely,
/s/ Jacob D. Steele
Show Raw Text
CORRESP 1 filename1.htm Document 12670 High Bluff Drive San Diego, California 92130 Tel: +1.858.523.5400 Fax: +1.858.523.5450 www.lw.com FIRM / AFFILIATE OFFICES Beijing Moscow Boston Munich Brussels New York Century City Orange County Chicago Paris Dubai Riyadh Düsseldorf San Diego Frankfurt San Francisco Hamburg Seoul Hong Kong Shanghai Houston Silicon Valley London Singapore Los Angeles Tokyo Madrid Washington, D.C. Milan July 2, 2020 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Life Sciences 100 F Street N.E. Washington, D.C. 20549 Attn: Chris Edwards Re: PDL BioPharma, Inc. Revised Preliminary Proxy Statement on Schedule 14A Filed on June 30, 2020 File No. 000-19756 Ladies and Gentlemen: We are in receipt of the letter from the staff of the Securities and Exchange Commission (the “Staff”) dated July 2, 2020 (the “Third Letter”) with respect to the above-referenced Revised Preliminary Proxy Statement (the “Revised Preliminary Proxy Statement”). We are responding to the Staff’s comments on behalf of PDL BioPharma, Inc. (the “Company”) as set forth below. The Company’s response set forth in this letter is numbered to correspond to the comment in the Third Letter. All terms used but not defined herein have the meanings assigned to such terms in the Revised Preliminary Proxy Statement. For ease of reference, we have set forth the Staff’s comment and the Company’s response below. Revised Preliminary Proxy Statement on Schedule 14A, filed on June 30, 2020 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. Company’s Response: The Company will revise the disclosure in the “Background of the Proposed Dissolution and Plan of Dissolution” section in response to the Staff’s comment by adding the following sentence to the Company’s definitive proxy statement: “As of the date of this proxy statement, we have not received any offer to purchase the entire company.” Please do not hesitate to contact me at (858) 523-3950 with any questions or comments regarding this correspondence. Thank you in advance for your cooperation in connection with this matter. Sincerely, /s/ Jacob D. Steele Jacob D. Steele of LATHAM & WATKINS LLP cc: Christopher Stone, PDL BioPharma, Inc. Nathan Kryszak, PDL BioPharma, Inc. Edward Imbrogno, PDL BioPharma, Inc. Cheston J. Larson, Latham & Watkins LLP Michael A. Treska, Latham & Watkins LLP Christopher G. Geissinger, Latham & Watkins LLP James Anderson, PricewaterhouseCoopers LLP