SEC Comment Letter for BATTALION OIL CORP (BATL) (CIK 0001282648) (BATL) — Mar 9, 2017
BATTALION OIL CORP (BATL) (CIK 0001282648)
Date: March 9, 2017 · CIK: 0001282648 · Accession: 0000000000-17-007943
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35467
Letter
March 9 , 2017 Via E -mail William T. Heller IV, Esq. Mayer Brown LLP 700 Louisiana Street Suite 3400 Houston , TX 77002
Re: Halcó n Resources Corp oration Current Report on Form 8 -K Filed February 9 , 2017 File No . 001-35467
Dear Mr. Heller :
We have limited our review of the filing to the issue we have addressed in our comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, pleas e tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to th is comment , we may have additional comments.
Exhibit 99.1 – Press Release dated February 9, 2017 1. The press release appears to relate to a debt tender offer with an abbreviated offering period as described in the Abbreviated Tender or Exchange Offers for Non -Convertible Debt Securities no -action letter (Jan. 23, 2015); however, the press release does not contain an active hyperlink to, or an Internet address at which a holder could obtain, copies of the offer to purchase, letter of transmittal and other offer do cuments. Including this active hyperlink or Internet address in the press release is a necessary part of the “Immediate Widespread Dissemination” process set forth in the no -action lette r as a condition of the relief. Given these facts, please provide an analysis as to how the tender offer was consistent with Exchange Act Rule 14e-1(a).
We remind you that the filing persons are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
William T. Heller IV, Esq. Mayer Brown LLP March 9 , 2017 Page 2
Please direct any questions to me at (202) 551 -3619 or to David Orlic, Special Counsel, at (202) 551 -3503 . Please send all correspondence to us at the following ZIP code: 20549 -3628.
Sincerely,
/s/ Daniel F. Duchovny
Daniel F. Duchovny
Special Counsel
Office of Mergers & Acquisitions
Show Raw Text
March 9 , 2017
Via E -mail
William T. Heller IV, Esq.
Mayer Brown LLP
700 Louisiana Street
Suite 3400
Houston , TX 77002
Re: Halcó n Resources Corp oration
Current Report on Form 8 -K
Filed February 9 , 2017
File No . 001-35467
Dear Mr. Heller :
We have limited our review of the filing to the issue we have addressed in our comment .
In our comment , we may ask you to provide us with information so we may better understand
your disclosure.
Please respond to this letter by amending your filing, by providing the requested
information, or by advising us when you will provide the requested response. If you do not
believe our comment applies to your facts and circumstances or do not believe an amendment is
appropriate, pleas e tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to th is comment , we may have additional comments.
Exhibit 99.1 – Press Release dated February 9, 2017
1. The press release appears to relate to a debt tender offer with an abbreviated offering
period as described in the Abbreviated Tender or Exchange Offers for Non -Convertible
Debt Securities no -action letter (Jan. 23, 2015); however, the press release does not
contain an active hyperlink to, or an Internet address at which a holder could obtain,
copies of the offer to purchase, letter of transmittal and other offer do cuments. Including
this active hyperlink or Internet address in the press release is a necessary part of the
“Immediate Widespread Dissemination” process set forth in the no -action lette r as a
condition of the relief. Given these facts, please provide an analysis as to how the tender
offer was consistent with Exchange Act Rule 14e-1(a).
We remind you that the filing persons are responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
William T. Heller IV, Esq.
Mayer Brown LLP
March 9 , 2017
Page 2
Please direct any questions to me at (202) 551 -3619 or to David Orlic, Special Counsel,
at (202) 551 -3503 . Please send all correspondence to us at the following ZIP code: 20549 -3628.
Sincerely,
/s/ Daniel F. Duchovny
Daniel F. Duchovny
Special Counsel
Office of Mergers & Acquisitions