SEC Comment Letter 0000000000-23-003304 to BROADWIND, INC. (BWEN) (CIK 0001120370) (BWEN)
BROADWIND, INC. (BWEN) (CIK 0001120370)
Date: March 31, 2023 · CIK: 0001120370 · Accession: 0000000000-23-003304
AI Filing Summary & Sentiment
File numbers found in text: 001-34278
Letter
United States securities and exchange commission logo March 31, 2023 Patrick Gadson Partner Vinson & Elkins LLP The Grace Building 1114 Avenue of the Americas 32nd Floor New York, New York 10036 Re:BROADWIND, INC. PREC14A filed March 27, 2023 File No. 001-34278 Dear Patrick Gadson: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. PREC14A filed March 27, 2023 Questions and Answers about the Annual Meeting, page 2 1.Please revise the disclosure on page 7 related to the vote required on the election of directors to make it clear that a plurality vote standard will apply at this year's annual meeting. General 2.Please refile the proxy card so that it is clearly legible on EDGAR.
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 LastNamePatrick Gadson Comapany NameVinson & Elkins LLP March 31, 2023 Page 2 FirstName LastName Patrick Gadson Vinson & Elkins LLP March 31, 2023 Page 2 Please direct any questions to David Plattner, at 202-551-8094, or Christina Chalk, at 202-551-3263. Sincerely, Division of Corporation Finance Office of Mergers and Acquisitions
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United States securities and exchange commission logo
March 31, 2023
Patrick Gadson
Partner
Vinson & Elkins LLP
The Grace Building
1114 Avenue of the Americas
32nd Floor
New York, New York 10036
Re:BROADWIND, INC.
PREC14A filed March 27, 2023
File No. 001-34278
Dear Patrick Gadson:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments by providing the requested information or advise us as
soon as possible when you will respond. If you do not believe our comments apply to your facts
and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
PREC14A filed March 27, 2023
Questions and Answers about the Annual Meeting, page 2
1.Please revise the disclosure on page 7 related to the vote required on the election of
directors to make it clear that a plurality vote standard will apply at this year's annual
meeting.
General
2.Please refile the proxy card so that it is clearly legible on EDGAR.
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 LastNamePatrick Gadson
Comapany NameVinson & Elkins LLP
March 31, 2023 Page 2
FirstName LastName
Patrick Gadson
Vinson & Elkins LLP
March 31, 2023
Page 2
Please direct any questions to David Plattner, at 202-551-8094, or Christina Chalk, at
202-551-3263.
Sincerely,
Division of Corporation Finance
Office of Mergers and Acquisitions