SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

  March 28, 2014

Via E-Mail
Steve Wolosky , Esq.
Olshan Frome Wolosky LLP
Park Avenue Tower
65 East 55th Street
New York, NY  10022

RE: Hudson Global , Inc.
Preliminary Proxy Statement  filed by Lone Star Value Investors, LP,
  Lone Star Value Investors GP, LLC, Lone Star Value Management, LLC,
  Jeffrey E. Eberwein, Bradley L. Radoff and Richard K. Coleman, Jr.
Filed on March 19 , 2014
File No. 00 0-50129

Dear Mr. Wolosky :

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 bett er understand your
disclosure.

Please respond to this letter by amending your filing, by providing the requested
information, or by advising us when you will provide the requested response.  If you do not
believe our comments apply to your facts and circumstances or do not believe an amendment is
appropriate, please tell us why in your response.

After reviewing any am endment to your filing and the information you provide in
response to these comments, we may have additional comments.

Letter to Shareholders
1. The penultimate sentence of the first paragraph implies that the current Board lacks
“appropriate and relevant sk ill sets and a shared objective of enhancing value for the
benefit of all Hudson stockholders .”  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 with the factual support  for
this assertion .  In this regard, please note that the factual foundation offered  must be
reasonable.  See Note b. to  Rule 14a -9.
2. We note the statements about including “direct stockholder representatives” on the Board
and how your interests are “fully aligned” with the interests of other Hudson stockholders.
Please tell us, with a view towa rd revised disclosure, whether any of the shares over which

Steve Wolosky , Esq.
Olshan Frome Wolosky LLP
March 28, 2014
Page 2

 any participant  has beneficial ownership were acquired or are being held for the account of
unaffiliated third parties, such as clients.

Background to the Solicitation, page 4
3. Please refer to the penultimate bullet point on page 5.  The context of the disclosure
“despite Hudson’s long history of poor performance” suggests either :  (1) Mr. Marquez
actually stated that  quoted phrase  to Mr. Eberwein; or (2) the incumbent directors stated
that quoted phrase  to Mr. Marquez , who then relayed it to Mr. Eberwein .  If neither of
these is correct, please revise accordingly.

Reasons for the Solicitation, page 6
4. We note  the concerns listed .  For each,  please revise to clarify how your nominees would
address the concerns  identified .  For example, discuss “the actions that they believe are
necessary to enhance stockholder value,” as mentioned on page 10.  As another example,
explain whether  the nominees seek to be appointed to the Company’s compensation
committee so that compensation practices may be modified  and, if so, how  modified.
While we understand  that a stockholder representative should chair such c ommittee, it
remain s unclear if you mean one of your nominees should be chairman.

We Are Concerned With the Lack of Sufficient Stock Ownership . . ., page 8
5. Please support the characteriz ation  of cash compensation to directors as “genero us.”

Proposal Number 1:  Election of Directors, page 10
6. We noticed the disclosure that “[e]ach of the Nominees may be deemed to be a member of
the Group…for the purposes of Section 13(d)(3)…and accordingly may be deemed to
beneficially own the shares of common stock owned directly by the other members of the
Group.”  Please provide us with a brief legal analysis in support of this statement, or make
revisions to the disclosure to remove the implication that membership in a group alone,
without more, results in shared beneficial ownership among group members.  Ma ke
conforming changes to the section titled “Additional Participant Information” if  necessary .

Quorum; Broker Non -votes; Discretionary voting, page 15
7. The second paragraph indicates that brokers will not have discretionary authority to vote
on any of the proposals included in this filing.  The last paragraph on this page implies
that brokers will have discretionary authority to vote on proposal three.  Please reconcile ,
and disclose the support for any conclusion reached that  in a contested election, a broker
still may retain  discretionary authority to vote on any routine proposals to be  introduced
and voted upon at the meeting .

Steve Wolosky , Esq.
Olshan Frome Wolosky LLP
March 28, 2014
Page 3

 Incorporation by Referen ce, page 19
8. If the participants  intend to rely on Rule 14a -5(c), plea se disclose that fact.  Also, please
be advised that we believe reliance on Rule 14a -5(c) before the Company distributes the
information to security holders would be inappropriate.  Alternatively, if a decision is
made  to disseminate the proxy statement prior to the distribution of the Company’s proxy
statement, the participants  must undertake to provide the omitted information to security
holders.  Please advise as to the participants’  intent in this regard.

Solicitation of Proxies, page 17
9. We note that proxies will be solicited by mail, facsimile , telephone, telegraph, Internet, in
person and by advertisements.  Please be advised that all written soliciting materials,
including any scripts to be uses in soliciting proxies mu st be filed under the cover of
Schedule 14A on the date of first use.  Please confirm your understanding.

Form of Proxy Card
10. Refer to the third paragraph of the card in bold and capital letters.  A proxy may confer
discretionary authority with respect to matters as to which a choice is not specified by the
security holder provided that the form of proxy states in bold -face type how it is intended
to vote .  As currently written with bracketed draftin g language, the card does not appear to
specify how the shares will be voted with respect to Proposal  2.  Please revise accordingly.
Refer to Exchange Act Rule 14a -4(b)(1).  Please make corresponding chang es to the
proxy statement itself  to the extent necessary .

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filings to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requ ire.  Since the participants are in possession of
all facts relating to the disclosure, they are responsible for the accuracy and adequacy of the
disclosures they have made.

 In responding to our comments, please provide a written statement from each part icipant
acknowledging that:

 the participant is responsible for the adequacy and accuracy of the disclosure in the
filing;

 staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with re spect to the filing; and

 the participant may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.

Steve Wolosky , Esq.
Olshan Frome Wolosky LLP
March 28, 2014
Page 4

 Please direct any questions to  Nicholas P. Panos , Senior Special Counsel,  at (202) 551 -
3266 or me at (202) 551 -3641.

        Sincerely,

        /s/ Geoff Kruczek

        Geoff Kruczek
        Attorney -Advisor
        Office of Mergers & Acquisitions