SEC Comment Letter 0000000000-23-004865 to LIVEPERSON INC (LPSN) (CIK 0001102993) (LPSN)
LIVEPERSON INC (LPSN) (CIK 0001102993)
Date: May 9, 2023 · CIK: 0001102993 · Accession: 0000000000-23-004865
AI Filing Summary & Sentiment
File numbers found in text: 000-30141
Letter
United States securities and exchange commission logo May 9, 2023 Andrew Freedman Partner Olshan Frome Wolosky LLP 1325 Avenue of the Americas New York, NY 10019 Re:LivePerson, Inc. DFAN14A filed by Starboard Value LP et al. Filed on May 5, 2023 File No. 000-30141 Dear Andrew Freedman: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. 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. DFAN14A filed May 5, 2023 General 1.You must avoid issuing statements that directly or indirectly impugn the character, integrity or personal reputation or make charges of illegal, improper or immoral conduct without factual foundation. Provide us supplementally, or disclose, the factual foundation for the following statement: "Furthermore, Mr. LoCascio has been embroiled in his own scandals, notably being included in Jeffrey Epstein’s 'Black Book' and having public associations with convicted criminal Ghislaine Maxwell." Additionally, in your response please provide more specificity about these "public associations." In this regard, note that the factual foundation for such assertions must be reasonable. Refer to Rule 14a-9. 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.
FirstName LastNameAndrew Freedman Comapany NameOlshan Frome Wolosky LLP May 9, 2023 Page 2 FirstName LastName Andrew Freedman Olshan Frome Wolosky LLP May 9, 2023 Page 2 Please direct any questions to Michael Killoy at (202) 551-7576 or Daniel Duchovny at (202) 551-3619. Sincerely, Division of Corporation Finance Office of Mergers & Acquisitions
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United States securities and exchange commission logo
May 9, 2023
Andrew Freedman
Partner
Olshan Frome Wolosky LLP
1325 Avenue of the Americas
New York, NY 10019
Re:LivePerson, Inc.
DFAN14A filed by Starboard Value LP et al.
Filed on May 5, 2023
File No. 000-30141
Dear Andrew Freedman:
We have reviewed your filing and have the following comment. In our comment, we may
ask you to provide us with information so we may better understand your disclosure.
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.
DFAN14A filed May 5, 2023
General
1.You must avoid issuing statements that directly or indirectly impugn the character,
integrity or personal reputation or make charges of illegal, improper or immoral conduct
without factual foundation. Provide us supplementally, or disclose, the factual foundation
for the following statement: "Furthermore, Mr. LoCascio has been embroiled in his own
scandals, notably being included in Jeffrey Epstein’s 'Black Book' and having public
associations with convicted criminal Ghislaine Maxwell." Additionally, in your response
please provide more specificity about these "public associations." In this regard, note that
the factual foundation for such assertions must be reasonable. Refer to Rule 14a-9.
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.
FirstName LastNameAndrew Freedman
Comapany NameOlshan Frome Wolosky LLP
May 9, 2023 Page 2
FirstName LastName
Andrew Freedman
Olshan Frome Wolosky LLP
May 9, 2023
Page 2
Please direct any questions to Michael Killoy at (202) 551-7576 or Daniel Duchovny at
(202) 551-3619.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions