SEC Comment Letter for BATTALION OIL CORP (BATL) (CIK 0001282648) (BATL) — Jul 31, 2017
BATTALION OIL CORP (BATL) (CIK 0001282648)
Date: July 31, 2017 · CIK: 0001282648 · Accession: 0000000000-17-026923
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4628 July 31, 2017 Mark J. Mize Executive Vice President, Chief Financial Officer and Treasurer Halcón Resources Corporation 1000 Louisiana St., Suite 6700 Houston, TX 77002
Re: Halcón Resources Corporation Information Statement on Form PRE 14C Filed July 26 , 2017 File No. 1-35467
Dear Mr. Mize :
We have reviewed your filing an d have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
General
1. Based on the disclosure contained on page 9 of the Information Statement, it appears that you solicited 25 shareholders representing approximately 53.9 % of your issued and outstanding common stock to execute written consents approving the divestiture of your Williston Basin assets . It does not appear that you filed materials regarding that solicitation. Please advise us of the consideration that you gave to the requirements of Rule 14a -2(b) under Regulation 14A. Your analysis should provide a legal analysis detailing how you obtai ned these shareholder consents in a manner that did not constitute a solicitation subject to the proxy rules. Alternatively, please file a preliminary proxy statement on Schedule 14A.
Mark J. Mize Halcón Resources Corporation July 31, 2017 Page 2
Closing Comments
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please contact Parhaum J. Hamidi, Attorney -Adviser , at (202) 551 -3421 or, in his absence, the undersigned at (202) 551 -3745 with any questions.
Sincerely,
/s/H. Roger Schwall
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Mail Stop 4628 July 31, 2017 Mark J. Mize Executive Vice President, Chief Financial Officer and Treasurer Halcón Resources Corporation 1000 Louisiana St., Suite 6700 Houston, TX 77002 Re: Halcón Resources Corporation Information Statement on Form PRE 14C Filed July 26 , 2017 File No. 1-35467 Dear Mr. Mize : We have reviewed your filing an d have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. General 1. Based on the disclosure contained on page 9 of the Information Statement, it appears that you solicited 25 shareholders representing approximately 53.9 % of your issued and outstanding common stock to execute written consents approving the divestiture of your Williston Basin assets . It does not appear that you filed materials regarding that solicitation. Please advise us of the consideration that you gave to the requirements of Rule 14a -2(b) under Regulation 14A. Your analysis should provide a legal analysis detailing how you obtai ned these shareholder consents in a manner that did not constitute a solicitation subject to the proxy rules. Alternatively, please file a preliminary proxy statement on Schedule 14A. Mark J. Mize Halcón Resources Corporation July 31, 2017 Page 2 Closing Comments We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Parhaum J. Hamidi, Attorney -Adviser , at (202) 551 -3421 or, in his absence, the undersigned at (202) 551 -3745 with any questions. Sincerely, /s/H. Roger Schwall H. Roger Schwall Assistant Director Office of Natural Resources