SEC Comment Letter 0000000000-24-013040 to MARTIN MIDSTREAM PARTNERS L.P. (MMLP)
MARTIN MIDSTREAM PARTNERS L.P.
Date: Nov. 25, 2024 · CIK: 0001176334 · Accession: 0000000000-24-013040
AI Filing Summary & Sentiment
File numbers found in text: 000-50056
Letter
November 25, 2024 Robert D. Bondurant President and Chief Executive Officer Martin Midstream Partners L.P. 4200 B Stone Road Kilgore, TX 75662 Re:Martin Midstream Partners L.P. Schedule 13E-3/A filed November 21, 2024 File No. 005-80397 Revised Preliminary Proxy Statement on Schedule 14A filed November 21, 2024 File No. 000-50056 Dear Robert D. Bondurant: 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. Schedule 13E-3/A and Revised Preliminary Proxy Statement on Schedule 14A, each filed November 21, 2024 General We note your response to prior comment 1. We disagree with your apparent conclusion that the actions of the Parent Group Support Entities, Mr. Martin, and Senterfitt outlined in our prior comment 1 were either addressed in their respective then-existing Schedule 13D disclosures or did not constitute a material change to the disclosures then in effect. Please be advised that amendments to Schedule 13D are regulated under Section 13(d)(2) of the Exchange Act and corresponding Rule 13d- 2(a). Consequently, disclosure regarding a plan or proposal under Item 4 of Schedule 13D may need to be made in advance of the submission of a proposal to acquire securities of an issuer. Generic disclosure of the type included in the Schedules 13D or reserving the right to engage in any of the kinds of transactions identified in Item 4(a)-(j) of Schedule 13D must be amended to the extent the facts previously reported 1.
November 25, 2024 Page 2 have materially changed. Refer to Exchange Act Sections 13(d) and 13(g) and Regulation 13D-G Beneficial Ownership Reporting Compliance and Disclosure Interpretations at Question 110.06. 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 Brian Soares at 202-551-3690 or Perry Hindin at 202- 551-3444. Sincerely, Division of Corporation Finance Office of Mergers & Acquisitions
Show Raw Text
November 25, 2024
Robert D. Bondurant
President and Chief Executive Officer
Martin Midstream Partners L.P.
4200 B Stone Road
Kilgore, TX 75662
Re:Martin Midstream Partners L.P.
Schedule 13E-3/A filed November 21, 2024
File No. 005-80397
Revised Preliminary Proxy Statement on Schedule 14A filed November 21, 2024
File No. 000-50056
Dear Robert D. Bondurant:
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.
Schedule 13E-3/A and Revised Preliminary Proxy Statement on Schedule 14A, each filed
November 21, 2024
General
We note your response to prior comment 1. We disagree with your apparent
conclusion that the actions of the Parent Group Support Entities, Mr. Martin, and
Senterfitt outlined in our prior comment 1 were either addressed in their respective
then-existing Schedule 13D disclosures or did not constitute a material change to the
disclosures then in effect. Please be advised that amendments to Schedule 13D are
regulated under Section 13(d)(2) of the Exchange Act and corresponding Rule 13d-
2(a). Consequently, disclosure regarding a plan or proposal under Item 4 of Schedule
13D may need to be made in advance of the submission of a proposal to acquire
securities of an issuer. Generic disclosure of the type included in the Schedules 13D
or reserving the right to engage in any of the kinds of transactions identified in Item
4(a)-(j) of Schedule 13D must be amended to the extent the facts previously reported 1.
November 25, 2024
Page 2
have materially changed. Refer to Exchange Act Sections 13(d) and 13(g) and
Regulation 13D-G Beneficial Ownership Reporting Compliance and Disclosure
Interpretations at Question 110.06.
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 Brian Soares at 202-551-3690 or Perry Hindin at 202-
551-3444.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions