SEC Comment Letter for BATTALION OIL CORP (BATL) (CIK 0001282648) (BATL) — Mar 28, 2017
BATTALION OIL CORP (BATL) (CIK 0001282648)
Date: March 28, 2017 · CIK: 0001282648 · Accession: 0000000000-17-010147
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35467
Letter
March 22, 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 Responses to comments on Current Report on Form 8 -K filed February 9 , Filed on March 14, 2017 File No . 001-35467
Dear Mr. Heller :
We have reviewed your response and have the following comment.
Exhibit 99.1 – Press Release dated February 9, 2017 1. We have reviewed your response to our prior comment regarding Halc ón Resources’ adherence to the criteria set forth in the Abbreviated Tender or Exchange Offers for Non - Convertible Debt Securities no -action letter (Jan. 23, 2015) in conducting its tender offer for 8.625% Senior Secured Notes due 2020, which commenced on February 9, 2017. The ability of a company to conduct a five business day tender offer in reliance on the letter is conditioned on the company’s satisfaction of each of the criteria set forth in the letter. In light of Halc ón Resources’ failure to comply with the Immediate Widespread Dissemination requirement with respect to its tender offer, please note that the no -action position expressed in the letter with respect to Exchange Act Rule 14e -1(a), which requires a minimum offer period of 20 business days for all tender offers, does not extend to Halc ón Resources’ tender offer. 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
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March 22, 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
Responses to comments on Current Report on Form 8 -K filed February 9 ,
2017
Filed on March 14, 2017
File No . 001-35467
Dear Mr. Heller :
We have reviewed your response and have the following comment.
Exhibit 99.1 – Press Release dated February 9, 2017
1. We have reviewed your response to our prior comment regarding Halc ón Resources’
adherence to the criteria set forth in the Abbreviated Tender or Exchange Offers for Non -
Convertible Debt Securities no -action letter (Jan. 23, 2015) in conducting its tender offer
for 8.625% Senior Secured Notes due 2020, which commenced on February 9, 2017. The
ability of a company to conduct a five business day tender offer in reliance on the letter is
conditioned on the company’s satisfaction of each of the criteria set forth in the letter. In
light of Halc ón Resources’ failure to comply with the Immediate Widespread
Dissemination requirement with respect to its tender offer, please note that the no -action
position expressed in the letter with respect to Exchange Act Rule 14e -1(a), which
requires a minimum offer period of 20 business days for all tender offers, does not extend
to Halc ón Resources’ tender offer.
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