SEC Comment Letter for BATTALION OIL CORP (BATL) (CIK 0001282648) (BATL) — Aug 15, 2017
BATTALION OIL CORP (BATL) (CIK 0001282648)
Date: Aug. 15, 2017 · CIK: 0001282648 · Accession: 0000000000-17-028764
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4628 August 14, 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 Response Dated August 2 , 2017 File No. 1-35467
Dear Mr. Mize :
We have reviewed your August 2, 2017 response to our comment letter and 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 wi ll 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. Unless we note otherwise, our references to prior comments are to comments in our July 31, 2017 letter .
General
1. In your response to comment 1, you stated that the individuals or entities became aware of the Williston Divestiture for reasons unrelated to their position as stockholders and unrelated to any solicitation of their written consent, and “volunteered ” their approval of the Williston Divestiture with res pect to their equity holdings of the Company. However, this statement appears to be inconsistent with your disclosure on page 1 of the information statement that, “In order to eliminate the costs and management time involved in obtaining proxies and in or der to effect these actions as early as possible to accomplish the purposes described below, the board of directors elected to seek the written consent of our stockholders in lieu of a special
Mark J. Mize Halcón Resources Corporation August 14, 2017 Page 2
meeting. ” Please revise the disclosure to clarify, if true, th at none of your communications regarding the Williston Divestiture with the individuals or entities listed on page 9 of the information statement involved a “solicitation” within the meaning of Rule 14a -1(l)(1).
Please contact Parhaum J. Hamidi, Attorney -Adviser , at (202) 551 -3421 or, in his absence, the undersigned at (202) 551 -3642 with any questions.
Sincerely,
/s/ Loan Lauren P. Nguyen for
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Mail Stop 4628 August 14, 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 Response Dated August 2 , 2017 File No. 1-35467 Dear Mr. Mize : We have reviewed your August 2, 2017 response to our comment letter and 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 wi ll 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. Unless we note otherwise, our references to prior comments are to comments in our July 31, 2017 letter . General 1. In your response to comment 1, you stated that the individuals or entities became aware of the Williston Divestiture for reasons unrelated to their position as stockholders and unrelated to any solicitation of their written consent, and “volunteered ” their approval of the Williston Divestiture with res pect to their equity holdings of the Company. However, this statement appears to be inconsistent with your disclosure on page 1 of the information statement that, “In order to eliminate the costs and management time involved in obtaining proxies and in or der to effect these actions as early as possible to accomplish the purposes described below, the board of directors elected to seek the written consent of our stockholders in lieu of a special Mark J. Mize Halcón Resources Corporation August 14, 2017 Page 2 meeting. ” Please revise the disclosure to clarify, if true, th at none of your communications regarding the Williston Divestiture with the individuals or entities listed on page 9 of the information statement involved a “solicitation” within the meaning of Rule 14a -1(l)(1). Please contact Parhaum J. Hamidi, Attorney -Adviser , at (202) 551 -3421 or, in his absence, the undersigned at (202) 551 -3642 with any questions. Sincerely, /s/ Loan Lauren P. Nguyen for H. Roger Schwall Assistant Director Office of Natural Resources