Correspondence 0001104659-22-127607 from ISTAR INC. (SAFE) (CIK 0001095651) (SAFE)
ISTAR INC. (SAFE) (CIK 0001095651)
Date: Dec. 16, 2022 · CIK: 0001095651 · Accession: 0001104659-22-127607
AI Filing Summary & Sentiment
Letter
CLIFFORD CHANCE US LLP
31 WEST 52ND STREET
NEW YORK, NY 10019-6131
TEL +1 212 878 8000
FAX +1 212 878 8375
www.cliffordchance.com
December 16, 2022
Via EDGAR Filing
Re: iStar Inc. Registration Statement on Form S-4
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Ladies and Gentlemen:
On behalf of iStar Inc., a Maryland corporation, we hereby transmit for filing under the Securities Act of 1933, as amended, a registration statement on Form S-4 relating to the registration of shares to be issued by iStar to the stockholders of Safehold Inc., a Maryland corporation, in connection with the previously-announced all-stock merger between iStar and Safehold pursuant to the Agreement and Plan of Merger, dated August 10, 2022.
For the information of the staff of the Securities and Exchange Commission, we have also transmitted for filing today a Form 10 registration statement for Star Holdings, a Maryland statutory trust. Star Holdings is currently a wholly-owned subsidiary of iStar that has been formed to own and manage certain assets of iStar that will be separated from iStar prior to the merger of iStar and Safehold. iStar plans to distribute all of the common equity interests of Star Holdings to the stockholders of iStar shortly before the closing of the merger.
The filing fee for the S-4 Registration Statement in the amount of $199,489.55 has been paid in full.
If you have any questions about the above-referenced S-4 Registration Statement, please contact Kathleen L. Werner of Clifford Chance US LLP, counsel to iStar, at (212) 878-8526.
Very truly yours,
/s/ Kathleen L. Werner
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CLIFFORD CHANCE US LLP
31 WEST 52ND STREET
NEW YORK, NY 10019-6131
TEL +1 212 878 8000
FAX +1 212 878 8375
www.cliffordchance.com
December 16, 2022
Via EDGAR Filing
Re: iStar
Inc. Registration Statement on Form S-4
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Ladies and Gentlemen:
On behalf of iStar Inc., a Maryland
corporation, we hereby transmit for filing under the Securities Act of 1933, as amended, a registration statement on Form S-4 relating
to the registration of shares to be issued by iStar to the stockholders of Safehold Inc., a Maryland corporation, in connection with the
previously-announced all-stock merger between iStar and Safehold pursuant to the Agreement and Plan of Merger, dated August 10, 2022.
For the information of the staff
of the Securities and Exchange Commission, we have also transmitted for filing today a Form 10 registration statement for Star Holdings,
a Maryland statutory trust. Star Holdings is currently a wholly-owned subsidiary of iStar that has been formed to own and manage certain
assets of iStar that will be separated from iStar prior to the merger of iStar and Safehold. iStar plans to distribute all of the common
equity interests of Star Holdings to the stockholders of iStar shortly before the closing of the merger.
The filing fee for the S-4 Registration
Statement in the amount of $199,489.55 has been paid in full.
If you have any questions about
the above-referenced S-4 Registration Statement, please contact Kathleen L. Werner of Clifford Chance US LLP, counsel to iStar, at (212) 878-8526.
Very truly yours,
/s/ Kathleen L. Werner
Kathleen L. Werner, Esq.
Clifford Chance US LLP