SecProbe.io

Filing text and metadata
Intelligence Terminal Search Topics Monthly Activity About

SEC Comment Letter 0000000000-24-002292 to CROWN CASTLE INC. (CCI)

CROWN CASTLE INC.
Date: Feb. 29, 2024 · CIK: 0001051470 · Accession: 0000000000-24-002292

Regulatory Compliance Financial Reporting Related Party / Governance

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 001-16441

Date
February 29, 2024
Author
Shane Callaghan
Form
UPLOAD
Company
CROWN CASTLE INC.

Letter

United States securities and exchange commission logo February 29, 2024 Theodore B. Miller, Jr. Co-Managing Member of 4M Management Partners, LLC Boots Parallel 1, LP c/o 4M Management Partners, LLC 7800 Washington Ave., Suite 700 Houston, TX 77007 Re:Boots Parallel 1, LP Crown Castle Inc. DFAN14A Filed February 28, 2024 Filed By Boots Parallel 1, LP et. al. File No. 001-16441 Dear Theodore B. Miller: We have reviewed your filing and have the following comment. Please respond to this comment 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 this comment, we may have additional comments. Defined terms used here have the same meaning as in your proxy statement. DFAN14A Filed February 28, 2024 Press Release Dated February 28, 2024 1.We note your assertion that the cooperation agreement "does not require Elliott to retain equity ownership in the Company" and Elliott is not "required to maintain an equity ownership position in the Company." However, Section 6 of the cooperation agreement requires Elliott to maintain a net long position of at least 1.0% in the Company's outstanding common stock. Please revise by issuing corrective disclosure in a new press release, or advise. We remind you that the filing persons are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please direct any questions to Shane Callaghan at 202-551-6977 or Christina Chalk at

FirstName LastNameTheodore B. Miller, Jr. Comapany NameBoots Parallel 1, LP February 29, 2024 Page 2 FirstName LastName Theodore B. Miller, Jr. Boots Parallel 1, LP February 29, 2024 Page 2 202-551-3263. Sincerely, Division of Corporation Finance Office of Mergers & Acquisitions

Show Raw Text
United States securities and exchange commission logo
February 29, 2024
Theodore B. Miller, Jr.
Co-Managing Member of 4M Management Partners, LLC
Boots Parallel 1, LP
c/o 4M Management Partners, LLC
7800 Washington Ave., Suite 700
Houston, TX 77007
Re:Boots Parallel 1, LP
Crown Castle Inc.
DFAN14A Filed February 28, 2024
Filed By Boots Parallel 1, LP et. al.
File No. 001-16441
Dear Theodore B. Miller:
            We have reviewed your filing and have the following comment.
            Please respond to this comment 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 this comment, we may have additional comments.
Defined terms used here have the same meaning as in your proxy statement.
DFAN14A Filed February 28, 2024
Press Release Dated February 28, 2024
1.We note your assertion that the cooperation agreement "does not require Elliott to retain
equity ownership in the Company" and Elliott is not "required to maintain an equity
ownership position in the Company."  However, Section 6 of the cooperation agreement
requires Elliott to maintain a net long position of at least 1.0% in the Company's
outstanding common stock.  Please revise by issuing corrective disclosure in a new press
release, or advise.
            We remind you that the filing persons are responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please direct any questions to Shane Callaghan at 202-551-6977 or Christina Chalk at

 FirstName LastNameTheodore B. Miller, Jr.
 Comapany NameBoots Parallel 1, LP
 February 29, 2024 Page 2
 FirstName LastName
Theodore B. Miller, Jr.
Boots Parallel 1, LP
February 29, 2024
Page 2
202-551-3263.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions