SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C.  20549

       DIVISION OF
CORPORATION FINANCE

 May 14 , 2020

Richard M. Brand , Esq.
Cadwalader, Wickersham & Taft LLP
200 Liberty Street
New York, NY 10281

 Re: Mack -Cali Realty Corporation
DFAN 14A filed May 12 , 2020  by Bow Street LLC et al.
  File No.  001-13274

Dear Mr. Brand :

We have reviewed the above -captioned  filing , and have the following comment s.  Our
comment s may ask for additional information so that we may better understand the disclosure.

Please respond to this letter by amending the filing and/or by providing the requested
information.  If you do not believe our comment s apply  to your facts and circumstances and/or
do not believe an amendment is appropriate, please tell us why in a written  response.

  After reviewing any amendment to the filing and any information provide d in response t o
these  comment s, we may have additional comments.   Capitalized terms used but not defined
herein have the same meaning ascribed to them in the filing.

1. We note the following statements:

 “Lead Independent Director Alan Bernikow and Chief Executive Officer Michael
DeMarco are unilaterally  seeking to replace the four highly qualified,  independent
directors nominated by Bow Street and duly elected by sh areholders less than a year
ago” (emphasis added) .

 “Mack -Cali’s proposed replacement directors have been hand -picked  by a
subcommittee of the Board of Directors (the “Board”) led by Mr. DeMarco and its
two longest serving directors – Mr. Bernikow and Irvin Reid – both of whom have
failed to provide proper oversight throughout their res pective 16 - and 26 -year
tenures ” (emphasis added).

In light of the apparent involvement of multiple independent directors  and Ferguson Part ners
in the director sel ection process, please provide us with a factual  basis for the claims above ,
or file corrective disclosure.

Richard M. Brand , Esq.
May 14, 2020
Page 2

 2. We note the following disclosure:

 “Furthermore, in 2019, Ferguson Partners began working directly with Ms. Jones and
her sp ouse on an initiative to promote ethnic diversity on public company boards.  It
was in the context of this initiative – and this context only – that Ms. Jones provided
her spouse’s name to Ferguson Partners. ”

It has come to our attention that Ms. Jones on multiple occasions  recommend ed to Ferguson
Partners that  her husband be considered as a candidate  for the Mack -Cali board  of directors ,
including  as recently as March 5, 2020 , without reference to the initiative  referred to above
or the existence  of Ms. Jones ’s relationship with the candidate .  Please clarify the above
disclosure  accordingly , or advise .

We remind you that the p articipants are responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

You may contact  me at (202) 551 -8094  with any questions.

Sincerely,

        /s/ David M. Plattner

David M. Plattner
Special Counsel
Office of Mergers and Acquisitions