SEC Comment Letter for Star Equity Holdings, Inc. (STRR, STRRP) (CIK 0001210708) (STRR) — Apr 19, 2019
Star Equity Holdings, Inc. (STRR, STRRP) (CIK 0001210708)
Date: April 19, 2019 · CIK: 0001210708 · Accession: 0000000000-19-007382
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38704
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE April 19 , 201 9 Jeffrey E. Eberwein Chief Executive Officer Hudson Global, Inc. 53 Forest Avenue Old Greenwich, CT 06870
Re: Hudson Global , Inc. DEFA 14A filing made under cover of Schedule 14A Filed on April 18 , 2019 by Hudson Global , Inc. File No. 001-38704
Dear M r. Eberwein ,
We have reviewed the above -captioned filing , and have the following comment . Our comment may ask for additional information so that we may better understand the disclosure.
Please respond to this letter by amending the filing and/or by providing the requested information. If you do not believe our comment applies to your facts and circumstances , and/or do not believe an amendment is appropriate, please tell us why in a written response.
After reviewing any amendment to the filing and any information provide d in response to thi s comment , we may have additional comments.
Schedule 14A | Definitive Additional Materials
1. The cover page has characterized the submission as “Definitive Additional Materials ” instead of “Definitive Proxy Statement, ” and the Schedule 14A has been altered in comparison to what form the U.S. Securities and Exchange Commission codified at Rule 14a -101. As a result of this apparent elective edit, the entry space for the amendment number has been deleted. The substantive content of the submission characterizes the filing as a “Supplement to the Proxy Statement ” and further represents that the supplement revises the definitive proxy statement. Please advise us, with a view toward revised disclosure, why the submission was not identified as Amendment No. 1 to the Definitive Proxy Statement and designated on EDGAR using the header tag DEFR14A. To the extent no revised submission is made, please provide us with a brie f legal analysis explaining why Hudson Global believes the existing submission lawfully amends the definitive proxy statement as represented in bold typeface when it appears to have been filed pursuant to Rule 14a -6(c).
We remind you that the registrant is responsible for the accuracy and adequacy of its disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Jeffrey E . Eberwein Hudson Global, Inc. April 19, 2019 Page 2
You may contact me at (202) 551 -3266 with any questions.
Sincerely,
/s/ Nicholas P. Panos
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
April 19 , 201 9
Jeffrey E. Eberwein
Chief Executive Officer
Hudson Global, Inc.
53 Forest Avenue
Old Greenwich, CT 06870
Re: Hudson Global , Inc.
DEFA 14A filing made under cover of Schedule 14A
Filed on April 18 , 2019 by Hudson Global , Inc.
File No. 001-38704
Dear M r. Eberwein ,
We have reviewed the above -captioned filing , and have the following comment . Our
comment may ask for additional information so that we may better understand the disclosure.
Please respond to this letter by amending the filing and/or by providing the requested
information. If you do not believe our comment applies to your facts and circumstances , and/or do
not believe an amendment is appropriate, please tell us why in a written response.
After reviewing any amendment to the filing and any information provide d in response to thi s
comment , we may have additional comments.
Schedule 14A | Definitive Additional Materials
1. The cover page has characterized the submission as “Definitive Additional Materials ” instead
of “Definitive Proxy Statement, ” and the Schedule 14A has been altered in comparison to
what form the U.S. Securities and Exchange Commission codified at Rule 14a -101. As a
result of this apparent elective edit, the entry space for the amendment number has been
deleted. The substantive content of the submission characterizes the filing as a “Supplement
to the Proxy Statement ” and further represents that the supplement revises the definitive
proxy statement. Please advise us, with a view toward revised disclosure, why the
submission was not identified as Amendment No. 1 to the Definitive Proxy Statement and
designated on EDGAR using the header tag DEFR14A. To the extent no revised submission
is made, please provide us with a brie f legal analysis explaining why Hudson Global believes
the existing submission lawfully amends the definitive proxy statement as represented in bold
typeface when it appears to have been filed pursuant to Rule 14a -6(c).
We remind you that the registrant is responsible for the accuracy and adequacy of its
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Jeffrey E . Eberwein
Hudson Global, Inc.
April 19, 2019
Page 2
You may contact me at (202) 551 -3266 with any questions.
Sincerely,
/s/ Nicholas P. Panos
Nicholas P. Panos
Senior Special Counsel
Office of Mergers & Acquisitions
cc: Lawrence S. Elbaum , Esq.