SEC Comment Letter 0000000000-24-002636 to Whitestone REIT (WSR)
Whitestone REIT
Date: March 11, 2024 · CIK: 0001175535 · Accession: 0000000000-24-002636
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File numbers found in text: 001-34855
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United States securities and exchange commission logo
March 11, 2024
Peter Tropoli
General Counsel & Corporate Secretary
Whitestone REIT
2600 S. Gessner Road, Suite 500
Houston, TX 77063-3223
Re:Whitestone REIT
DEFA14A filed March 7, 2024
File No. 001-34855
Dear Peter Tropoli:
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.
DEFA14A filed March 7, 2024
General
1.Communications made in reliance on Rule 14a-12 must identify the participants in the
solicitation and describe the participants’ “direct or indirect interests.” Please note that
the legend must advise security holders where they can currently obtain such information,
which requirement is not satisfied by including a general reference to filings made by the
soliciting party. In this respect, we note your statements that "[i]nformation regarding
the ownership of the Company’s trustees and executive officers in Company common
shares and other securities is included in their SEC filings on Forms 3, 4, and 5..." and
"[i]nformation can also be found in the Company’s other SEC filings, including the
Company’s Annual Report on Form 10-K." Please revise to provide more specific
references. Refer to Rule 14a-12(a)(1)(i) and Question 132.03 of the Compliance and
Disclosure Interpretations for Proxy Rules and Schedules 14A/14C, available
at https://www.sec.gov/corpfin/proxy-rules-schedules-14a-14c-cdi.htm.
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 LastNamePeter Tropoli
Comapany NameWhitestone REIT
March 11, 2024 Page 2
FirstName LastName
Peter Tropoli
Whitestone REIT
March 11, 2024
Page 2
Please direct any questions to David Plattner at 202-551-8094.
Sincerely,
Division of Corporation Finance
Office of Mergers and Acquisitions