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CORRESP
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        December 4, 2023

        VIA EMAIL AND EDGAR

        Blake Grady

          Daniel Duchovny

          Office of Mergers and Acquisitions

          Division of Corporation Finance

          U.S. Securities and Exchange Commission

          100 F Street, NE

          Washington, D.C. 20549-3628

              Re:

                StarTek, Inc.

                  Schedule 13E-3 filed November 3, 2023 by CSP Management II Limited et al.

                  File No. 005-52745

                  Preliminary Information Statement filed November 3, 2023

                  File No. 001-12793

        Dear Messrs. Grady and Duchovny:

        On behalf of StarTek, Inc. (the “Company”) set forth below are responses to comments the staff (the “Staff”) of the Securities and Exchange Commission delivered by letter, dated
          November 27, 2023, with respect to the above referenced Schedule 13E-3 and Preliminary Information Statement (the “Comment Letter”). Filed concurrently herewith is Amendment No. 1 to the Schedule 13E-3 (the “Amended Schedule 13E-3”)
          and Amendment No. 1 to the Preliminary Information Statement (the “Revised Preliminary Information Statement”), containing changes and revisions in response to the Staff’s comments. Capitalized terms used but not defined in this letter
          have the meanings given to them in the Amended Schedule 13E-3 or the Revised Preliminary Information Statement, as applicable.

        The Company’s responses to the Staff’s comments are set forth below, with each paragraph numbered to correspond to the numbered comment in the Comment Letter. All references to page numbers
          and captions in these responses correspond to the Amended Schedule 13E-3 and the Revised Preliminary Information Statement, as applicable (except for such page numbers and captions included in the Staff’s transposed comments).

        Schedule 13E-3 filed November 3, 2023

          General

                1.

                  We note your disclosure in your Schedule 13E-3 that Item 12(d) is “[n]ot applicable.” In this respect, revise to
                      disclose whether or not any executive officer, director or affiliate of the Company (or any person specified in Instruction C to the schedule) currently intends sell subject securities owned or held by that person. Refer to Item
                      1012(d) of Regulation M-A.

          Response:

          In response to the Staff’s comment, the Company has revised the disclosure on page 38 of the Revised Preliminary Information Statement to state that, as of the date of the Revised Preliminary Information Statement,
            to the knowledge of the filing persons, no executive officer, director or affiliate of the Company intends to sell any shares of Company Common Stock owned or held by them prior to the Closing, and in connection with the Closing, such shares of
            Company Common Stock will receive the Merger Consideration except in the case of shares of Company Common Stock owned or held by the CSP Parties, which will be cancelled without payment of any consideration therefor and cease to exist at the
            Effective Time.

          As discussed in the Revised Preliminary Information Statement, the Sponsor beneficially owned more than a majority of the issued and outstanding shares of Company Common Stock and more than a majority of voting
            power of capital stock of the Company, and has delivered the Sponsor Written Consent approving and adopting in all respects the Merger Agreement and the transactions contemplated thereby, including the Merger, which became effective at 6:00
            P.M. New York City time on November 9, 2023. Because the vote required under Delaware law to approve the Merger was obtained via written consent on November 9, 2023, no other future vote of the Company’s directors, executive officers or
            affiliates is required in connection with the Merger.

          Preliminary Information Statement filed November 3, 2023

          General

                2.

                  We note your disclosure that the Board “determined that the Merger Agreement and the transactions contemplated thereby, including the Merger, are advisable, fair
                    to, [and] in the best interests of the Company and the Unaffiliated Stockholders.” It appears that the definition of Unaffiliated Stockholders on the first page of the letter to stockholders includes within it directors and officers of
                    the Company who are not otherwise affiliated with Parent, Merger Sub or Sponsor, even though those individuals are considered affiliates of the Company under Rule 13e-3(a)(1). The definition of “Unaffiliated Stockholders” should
                    therefore exclude such persons, so that the disclosure speaks strictly to the fairness of the Merger to unaffiliated securityholders. Please revise throughout the information statement. See Item 1014(a) of Regulation M-A.

          Response:

          In response to the Staff’s comment, the Company has revised the definition of Unaffiliated Stockholders on the first page of the letter to stockholders to remove directors and officers of the Company so that the
            disclosure speaks strictly to the fairness of the Merger to unaffiliated securityholders.

                3.

                  Please revise to provide the summary financial statements required by Item 1010(c) of Regulation M-A in the information statement. See Instruction 1 to Item 13
                    of Schedule 13E-3.

          Response:

          In response to the Staff’s comment, the Company has provided the disclosure under the sections titled “Other Important Information Regarding the Company – Selected Historical Financial Data” beginning on page 78 of
            the Revised Preliminary Information Statement and “Other Important Information Regarding the Company – Book Value per Share” on page 79 of the Revised Preliminary Information Statement.

                  4.

                  General Instruction E to Schedule 13E-3 requires an affirmative statement as to whether or not any of the transactions described in Item 1005(a) occurred with
                    the past two years Please revise or advise.

          Response:

          In response to the Staff’s comment, the Company has provided the disclosure beginning on page 58 of the Revised Preliminary Information Statement under the section “Past Contacts, Transactions, Negotiations and
            Agreements”.

                5.

                  Please include, in an appropriate location in the information statement, the proceeds to be received by each director and officer with respect to shares of
                    Company Common Stock owned by such persons.

          Response:

          In response to the Staff’s comment, the Company has provided the disclosure on page 38 of the Revised Preliminary Information Statement under the section “Security Ownership of
              Certain Beneficial Owners and Management – Proceeds Received by the Company’s Directors and Executive Officers in connection with the Merger”.

                6.

                  Provide the disclosure required by Item 1005(e) of Regulation M-A in the information statement. As one example only, we note the disclosure in the Company’s 2023
                    annual report on Form 10-K that “[t]he Stockholders Agreement dated July 20, 2018, gives CSP the right to appoint a majority [of the] directors on [the Company’s] Board of Directors including the Chairman of the Board of Directors.” In
                    addition, file any such agreement as an exhibit to your Schedule 13E-3. See Item 16 of Schedule 13E-3 and Item 1016(d) of Regulation M-A.

          Response:

          In response to the Staff’s comment, the Company has provided the disclosure beginning on page 58 of the Revised Preliminary Information Statement under the section “Past Contacts, Transactions, Negotiations and
            Agreements”. In response to the Staff’s comment, the filing persons have filed such agreements as Exhibit No. (d)(2), Exhibit No. (d)(3) and Exhibit No. (d)(4) to the Amended Schedule 13E-3.

                7.

                  Please prominently disclose the information required by Items 7, 8 and 9 of Schedule 13E- 3 in a “Special Factors” section in the front of the information
                    statement. Refer to Rule 13e-3(e)(1)(ii). In this respect, ensure that the Special Factors appear immediately after the Summary. Also, revise the Summary and Q&A sections to shorten them significantly and to avoid duplication and
                    relocate the other sections currently appearing in front of the Special Factors.

          Response:

          The Company acknowledges the Staff’s comment and in response has inserted an overview of the “Special Factors” under the section “Special Factors – Overview of the Special Factors” on page 8 of the Revised
            Preliminary Information Statement that more clearly outlines where the information required by Items 7, 8 and 9 of Schedule 13E-3 can be found in the Revised Preliminary Information Statement.

          In response to the Staff’s comment, the Company has also moved the “Special Factors” section to immediately follow the Summary.

          In response to the Staff’s comment, the Company has shortened the Summary and Q&A sections. For example, please see “Summary—The Merger Agreement” on pages 5 and the Q&A Sections beginning on page 45 of the
            Revised Preliminary Information Statement, respectively, where certain duplicative disclosures have been shortened or removed.

          Directors, Executive Officers and Controlling Persons of the Company, page 19

                8.

                  Each filing person must individually comply with the filing, dissemination, disclosure and signature requirements of Schedule 13E-3. In this respect, we note
                    your disclosure on page 22 regarding CSP Management Limited. Please provide the disclosure required by Item 1003 of Regulation M-A with respect to each filing person, including CSP Management II Limited, and otherwise include all of the
                    information required by Schedule 13E-3 and its instructions for all filing persons.

          Response:

          The Company takes note of the Staff’s comment, and all disclosure required by Schedule 13E-3, including Item 1003 of Regulation M-A, has been provided for all filing persons in the Revised Preliminary Information
            Statement.

          Background of the Merger, page 23

                9.

                  We note your disclosure that on September 15, 2023, “representatives of Houlihan updated the Special Committee on Houlihan’s conversation with CSP” and that
                    “[f]ollowing Houlihan’s meeting with CSP on September 21, 2023, representatives of Houlihan updated the Special Committee on the Final Proposal.” Each presentation, discussion, or report held with or presented by the financial advisor,
                    whether oral or written, is a separate report that requires a reasonably detailed description meeting the requirements of Item 1015 of Regulation M-A. This requirement applies to both preliminary and final reports. If the above
                    statements reference a presentation made by Houlihan during the Special Committee’s evaluation of the transaction, please supplement the disclosure to provide a reasonably detailed description of such meeting that satisfies the
                    requirements of Item 1015 and file any written materials, if applicable, as exhibits to the Schedule 13E-3 pursuant to Item 9 of Schedule 13E-3 and Item 1016(c) of Regulation M-A. We note that there does not appear to be any such
                    written report dated September 15, 2023 or September 21, 2023 currently filed as an exhibit. Refer to Meyers Parking, Rel. 34-26069 (Sep. 12, 1980).

          Response:

          We respectfully advise the Staff that the Special Committee’s meetings and communications with its advisors on each of September 15, 2023 and September 21, 2023 were to communicate to the Special Committee the
            terms of the Revised Proposal and the Final Proposal, as applicable, and did not go into an analysis of the financial  terms of those proposals. Representatives of Houlihan presented Houlihan’s financial analyses with respect to the Revised
            Proposal and the Final Proposal at the Special Committee meetings held on September 20, 2023 and October 10, 2023, respectively, and the presentations reviewed at such meetings were filed as Exhibit No. (c)(2) and Exhibit No. (c)(3) to the
            initial Schedule 13E-3.

          Recommendation of the Special Committee; Recommendation of the Board; Reasons for the Merger, page 32

                10.

                  We note that the Board acted upon the recommendation of the Special Committee. We also note that the Special Committee considered the Houlihan analyses and
                    opinion. Note that if any filing person has based its fairness determination on the analysis of factors undertaken by others, such person must expressly adopt this analysis and discussion as their own to satisfy the disclosure
                    obligation. See Question 20 of Exchange Act Release No. 34-17719 (April 13, 1981). Please revise to state, if true, that the Special Committee adopted Houlihan’s analyses and conclusion as its own. Alternatively, revise your disclosure
                    to include disclosure responsive to Item 1014 of Regulation M-A and to address the factors listed in instruction 2 to Item 1014.

          Response:

          In response to the Staff’s comment, the Company has revised the disclosure on page 19 of the Revised Preliminary Information Statement to state that the Special Committee adopted Houlihan’s analyses and conclusions
            as its own.

                11.

                  Refer to the comment above. We note your disclosure that “the Board, acting upon the recommendation of the Special Committee, unanimously ... determined that the
                    terms of the Merger Agreement and the transactions contemplated thereby, including the Merger, are fair to, and in the best interests of, the Company and the Unaffiliated Stockholders.” Please revise to state, if true, that the Board
                    adopted the Special Committee’s analyses and opinion as its own. Alternatively, revise your disclosure to include disclosure responsive to Item 1014 of Regulation M-A and to address the factors listed in instruction 2 to Item 1014.

          Response:

          In response to the Staff’s comment, the Company has revised the disclosure on page 21 of the Revised Preliminary Information Statement to state that the Board adopted the Special Committee’s analyses and opinion as
            its own.

                12.

                  We note your statement that the Special Committee believed that “the Merger Consideration was the result of an arm’s-length negotiation.” Please delete all
                    references to “arm’s-length negotiations,” as such references are inappropriate in a going-private transaction by affiliates.

          Response:

          In response to the Staff’s comment, the Company has revised the disclosure on pages 18 and 34 of the Revised Preliminary Information Statement to delete all references to arm’s-length negotiations.

          Opinion of Houlihan, page 37

                13.

                  Please revise to disclose the data underlying the results described in this section and to show how that information resulted in the multiples and values
                    disclosed. For example, disclose (i) the estimated enterprise value for each