SEC Comment Letter for Star Equity Holdings, Inc. (STRR, STRRP) (CIK 0001210708) (STRR) — Apr 25, 2014
Star Equity Holdings, Inc. (STRR, STRRP) (CIK 0001210708)
Date: April 25, 2014 · CIK: 0001210708 · Accession: 0000000000-14-021171
AI Filing Summary & Sentiment
Reasoning
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE April 25, 2014 Via E-Mail John K. Wilson , Esq. Foley & Lardner LLP 777 East Wisconsin Avenue Milwaukee, WI 53202
RE: Hudson Global, Inc. Definitive Additional Materials Filed April 25, 2014 File No. 000 -50129
Dear Mr. Wilson :
We have reviewed your filing s and have the following comment . 1. Please provide support for the following statements: (i) supposed “flaws in [Lone Star’s] analysis,” which suggests Mr. Eberwein does not understand the Company’s business, as it is unclear to what flaws the Company is referring; (ii) how and why Lone Star’s proxy statement is “flawed and misleading,” in that it supposedly “vastly overstates” the Company’s pre -tax losses during Ms. Laing’s tenure; and (iii) how Lone Star’s proxy statement “blatantly misrepresents potential settlement discussions with Hudson’s Board.”
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings to be certa in 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 adeq uacy of the disclosures they have made.
Please direct any questions to Nicholas 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 25, 2014
Via E-Mail
John K. Wilson , Esq.
Foley & Lardner LLP
777 East Wisconsin Avenue
Milwaukee, WI 53202
RE: Hudson Global, Inc.
Definitive Additional Materials
Filed April 25, 2014
File No. 000 -50129
Dear Mr. Wilson :
We have reviewed your filing s and have the following comment .
1. Please provide support for the following statements: (i) supposed “flaws in [Lone Star’s]
analysis,” which suggests Mr. Eberwein does not understand the Company’s business, as
it is unclear to what flaws the Company is referring; (ii) how and why Lone Star’s proxy
statement is “flawed and misleading,” in that it supposedly “vastly overstates” the
Company’s pre -tax losses during Ms. Laing’s tenure; and (iii) how Lone Star’s proxy
statement “blatantly misrepresents potential settlement discussions with Hudson’s Board.”
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filings to be certa in 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 adeq uacy of the
disclosures they have made.
Please direct any questions to Nicholas 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