SEC Comment Letter for Star Equity Holdings, Inc. (STRR, STRRP) (CIK 0001210708) (STRR) — Feb 5, 2018
Star Equity Holdings, Inc. (STRR, STRRP) (CIK 0001210708)
Date: Feb. 5, 2018 · CIK: 0001210708 · Accession: 0000000000-18-003930
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-50129
Letter
February 2, 2018 Stephen A. Nolan Chief Executive Officer Hudson Global, Inc. 1325 Avenue of the Americas New York, NY 10019 Re:Hudson Global, Inc. Preliminary Proxy Statement on Schedule 14A Filed January 25, 2018 File No. 000-50129 Dear Mr. Nolan: We have reviewed your filing and have the following comment. Please respond to this comment within ten business days 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. Preliminary Proxy Statement on Schedule 14A General 1.Please tell us why the Sale Resolution proposal is not unbundled into three separate proposals. Provide your analysis under Rule 14a-4(a)(3) and (b)(1). Refer to our Compliance and Disclosure Interpretations 101.01 and 101.02 dated January 24, 2014 (regarding unbundling under Rule 14a-4(a)(3) generally). We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameStephen A. Nolan Comapany NameHudson Global, Inc. June 16, 2017 Page 2 FirstName LastName Stephen A. Nolan Hudson Global, Inc. February 2, 2018 Page 2 You may contact Joshua Shainess, Attorney-Adviser, at (202) 551-7951 or Celeste M. Murphy, Legal Branch Chief, at (202) 551-3257 with any questions. Division of Corporation Finance Office of Telecommunications
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February 2, 2018
Stephen A. Nolan
Chief Executive Officer
Hudson Global, Inc.
1325 Avenue of the Americas
New York, NY 10019
Re:Hudson Global, Inc.
Preliminary Proxy Statement on Schedule 14A
Filed January 25, 2018
File No. 000-50129
Dear Mr. Nolan:
We have reviewed your filing and have the following comment.
Please respond to this comment within ten business days 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.
Preliminary Proxy Statement on Schedule 14A
General
1.Please tell us why the Sale Resolution proposal is not unbundled into three separate
proposals. Provide your analysis under Rule 14a-4(a)(3) and (b)(1). Refer to our
Compliance and Disclosure Interpretations 101.01 and 101.02 dated January 24, 2014
(regarding unbundling under Rule 14a-4(a)(3) generally).
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
FirstName LastNameStephen A. Nolan
Comapany NameHudson Global, Inc.
June 16, 2017 Page 2
FirstName LastName
Stephen A. Nolan
Hudson Global, Inc.
February 2, 2018
Page 2
You may contact Joshua Shainess, Attorney-Adviser, at (202) 551-7951 or Celeste M.
Murphy, Legal Branch Chief, at (202) 551-3257 with any questions.
Division of Corporation Finance
Office of Telecommunications