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CORRESP Filing

Star Equity Holdings, Inc.
Date: July 18, 2025 · CIK: 0001210708 · Accession: 0001193125-25-161098

Offering / Registration Process

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File numbers found in text: 333-288531

Date
July 18, 2025
Author
Jeffrey E. Eberwein
Form
CORRESP
Company
Star Equity Holdings, Inc.

Letter

Re: Hudson Global, Inc. Registration Statement on Form S-4; File No. 333-288531 Request for Acceleration Ladies and Gentlemen: Reference is made to the Registration Statement on Form S-4 (File No. 333-288531) filed by Hudson Global, Inc. (the “ Company ”) with the U.S. Securities and Exchange Commission (the “ Commission ”) on July 3, 2025, as amended on July 17, 2025 (the “ Registration Statement ”). The Company hereby requests that the Registration Statement be made effective at 4:00 p.m., Eastern Time, on July 22, 2025, or as soon as possible thereafter, in accordance with Rule 461 under the Securities Act of 1933, as amended. Please contact Adam W. Finerman of Baker & Hostetler LLP at (212) 589-4233 or by email at afinerman@bakerlaw.com with any questions you may have concerning this request. The Company hereby authorizes Mr. Finerman to orally modify or withdraw this request for acceleration. We request that we be notified of such effectiveness by a telephone call to Mr. Finerman, and that such effectiveness also be confirmed in writing.

Hudson Global, Inc. 53 Forest Avenue, Suite 102 Old Greenwich, CT 06870 July 18, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attn: Nicholas Nalbantian

Very truly yours,
Hudson Global, Inc.

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CORRESP
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 CORRESP

 Hudson Global, Inc.
 53 Forest Avenue, Suite 102 Old
Greenwich, CT 06870 July 18, 2025
 VIA EDGAR U.S. Securities and Exchange Commission
 Division of Corporation Finance 100 F Street, N.E.
 Washington, D.C. 20549 Attn: Nicholas Nalbantian

 Re:
 Hudson Global, Inc.
 Registration Statement on Form S-4; File No. 333-288531
 Request for Acceleration Ladies and
Gentlemen: Reference is made to the Registration Statement on Form S-4 (File No. 333-288531) filed by Hudson Global, Inc. (the “ Company ”) with the U.S. Securities and Exchange Commission (the “ Commission ”) on July 3, 2025, as amended on
July 17, 2025 (the “ Registration Statement ”). The Company hereby requests that the Registration Statement be made
effective at 4:00 p.m., Eastern Time, on July 22, 2025, or as soon as possible thereafter, in accordance with Rule 461 under the Securities Act of 1933, as amended.
 Please contact Adam W. Finerman of Baker & Hostetler LLP at (212) 589-4233 or by email at
afinerman@bakerlaw.com with any questions you may have concerning this request. The Company hereby authorizes Mr. Finerman to orally modify or withdraw this request for acceleration.
 We request that we be notified of such effectiveness by a telephone call to Mr. Finerman, and that such effectiveness also be confirmed
in writing.

 Very truly yours,

 Hudson Global, Inc.

 By:

 /s/ Jeffrey E. Eberwein

 Jeffrey E. Eberwein

 Chief Executive Officer