SEC Comment Letter for Star Equity Holdings, Inc. (STRR, STRRP) (CIK 0001210708) (STRR) — Apr 8, 2014
Star Equity Holdings, Inc. (STRR, STRRP) (CIK 0001210708)
Date: April 8, 2014 · CIK: 0001210708 · Accession: 0000000000-14-017554
AI Filing Summary & Sentiment
Reasoning
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE April 8, 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, et al. Filed on April 7 , 2014 File No. 00 0-50129
Dear Mr. Wolosky :
We have reviewed your filing and have the following comment .
Proposal Number 1: Election of Directors, page 11 1. We note your revisions in response to prior comment 4. Please revise to provide more detail regarding the “operational turnaround plan,” which shareholder unfriendly provision s you will attempt to eliminate and how you intend to structure executive compensation. If you do not hav e a specific plan for each of the se actions, please revise to disclose that fact. Please also revise to clarify how you intend to address the concern on page 8 regarding directors’ lack of sufficient stock ownership .
We urge all persons who are re sponsible 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 require. 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.
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
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
April 8, 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, et al.
Filed on April 7 , 2014
File No. 00 0-50129
Dear Mr. Wolosky :
We have reviewed your filing and have the following comment .
Proposal Number 1: Election of Directors, page 11
1. We note your revisions in response to prior comment 4. Please revise to provide more
detail regarding the “operational turnaround plan,” which shareholder unfriendly
provision s you will attempt to eliminate and how you intend to structure executive
compensation. If you do not hav e a specific plan for each of the se actions, please revise to
disclose that fact. Please also revise to clarify how you intend to address the concern on
page 8 regarding directors’ lack of sufficient stock ownership .
We urge all persons who are re sponsible 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 require. 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.
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