SEC Comment Letter for ASHFORD HOSPITALITY TRUST INC (AHT, AHT-PD, AHT-PF, AHT-PG, AHT-PH, AHT-PI) (CIK 0001232582) (AHT) — Apr 29, 2015
ASHFORD HOSPITALITY TRUST INC (AHT, AHT-PD, AHT-PF, AHT-PG, AHT-PH, AHT-PI) (CIK 0001232582)
Date: April 29, 2015 · CIK: 0001232582 · Accession: 0000000000-15-023798
AI Filing Summary & Sentiment
File numbers found in text: 001-31775
Referenced dates: March 13, 2015
Letter
April 29 , 2015 Via E -mail Ms. JJ Fueser UNITE HERE 243 Golden Gate Avenue San Francisco, CA 94102
Re: Ashford Hospitality Trust, Inc. Definitive Additional Soliciting Materials Filed April 23 , 2015 by UNITE HERE File No. 001-31775
Dear Ms. Fueser :
We have reviewed your filing and have the following comment .
1. Please refer to d isclosure , which includes unqualified and inadequately supported assertion s that UNITE HERE “achieves better corporate governance in hospitality REITS since 2012” and “is improving corporate governance at lodging REITS.” Please refer to comment 9 of our initial letter dated March 13, 2015 and provide support for these statements. Also , in future soliciting material, qualify any s imilar statem ents as your opinion or belief and clarify the basis for your belief that there is a directly attributable causal link between an action you have taken and subsequent corporate governance improvements enacted by a company. We may have further comment.
You may contact me at (202) 551 -3589 or Mellissa Campbell Duru, Special Counsel, at (202) 551 -3757 if you have any questions regarding our comments .
Sincerely,
/s/ Tiffany Piland Posil
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April 29 , 2015
Via E -mail
Ms. JJ Fueser
UNITE HERE
243 Golden Gate Avenue
San Francisco, CA 94102
Re: Ashford Hospitality Trust, Inc.
Definitive Additional Soliciting Materials
Filed April 23 , 2015 by UNITE HERE
File No. 001-31775
Dear Ms. Fueser :
We have reviewed your filing and have the following comment .
1. Please refer to d isclosure , which includes unqualified and inadequately supported
assertion s that UNITE HERE “achieves better corporate governance in hospitality REITS
since 2012” and “is improving corporate governance at lodging REITS.” Please refer to
comment 9 of our initial letter dated March 13, 2015 and provide support for these
statements. Also , in future soliciting material, qualify any s imilar statem ents as your
opinion or belief and clarify the basis for your belief that there is a directly attributable
causal link between an action you have taken and subsequent corporate governance
improvements enacted by a company. We may have further comment.
You may contact me at (202) 551 -3589 or Mellissa Campbell Duru, Special Counsel, at
(202) 551 -3757 if you have any questions regarding our comments .
Sincerely,
/s/ Tiffany Piland Posil
Tiffany Piland Posil
Special Counsel
Office of Mergers and Acquisitions