SEC Company Response from BATTALION OIL CORP (BATL) (CIK 0001282648) (BATL) — Aug 16, 2017
BATTALION OIL CORP (BATL) (CIK 0001282648)
Date: Aug. 16, 2017 · CIK: 0001282648 · Accession: 0001104659-17-052200
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35467
Referenced dates: August 14, 2017, August 2, 2017
Letter
VIA EDGAR United States Securities and Exchange Commission Halcón Resources Corporation Information Statement on Form PRE 14C Filed July 26, 2017 File No. 001-35467
Re:
Dear Mr. Schwall:
This letter responds to the staff’s comment letter dated August 14, 2017 regarding Halcón Resources Corporation’s (the “Company”) Information Statement on Form PRE 14C (the “Information Statement”) filed with the U.S. Securities and Exchange Commission on July 26, 2017. For your convenience, your comment has been reproduced below, together with the response of the Company.
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 respect 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 order 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 meeting.” Please revise the disclosure to clarify, if true, that 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).
Response:
The Company confirms that its response letter dated August 2, 2017 (the “Prior Response Letter”) is accurate, and acknowledges that the referenced disclosure on page 1 of the Information Statement could be construed as inconsistent with the Prior Response Letter. In light of the staff’s comment, the Company proposes to delete the referenced disclosure on page 1 of the Information Statement, as the Company does not believe such statement is required to be included in the Information Statement pursuant to Schedule 14C (or Schedule 14A, to the extent applicable to Schedule 14C) and does not believe such statement to be materially additive to the other disclosures contained in the Information Statement.
If you have any questions or require additional information, please call the undersigned at (832) 538-0303 or email at mmize@halconresources.com.
Sincerely,
/s/ Mark J. Mize
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CORRESP 1 filename1.htm August 16, 2017 VIA EDGAR Mr. H. Roger Schwall United States Securities and Exchange Commission 100 F. Street, N.E. Washington, D.C. 20549 Re: Halcón Resources Corporation Information Statement on Form PRE 14C Filed July 26, 2017 File No. 001-35467 Dear Mr. Schwall: This letter responds to the staff’s comment letter dated August 14, 2017 regarding Halcón Resources Corporation’s (the “Company”) Information Statement on Form PRE 14C (the “Information Statement”) filed with the U.S. Securities and Exchange Commission on July 26, 2017. For your convenience, your comment has been reproduced below, together with the response of the Company. 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 respect 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 order 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 meeting.” Please revise the disclosure to clarify, if true, that 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). Response: The Company confirms that its response letter dated August 2, 2017 (the “Prior Response Letter”) is accurate, and acknowledges that the referenced disclosure on page 1 of the Information Statement could be construed as inconsistent with the Prior Response Letter. In light of the staff’s comment, the Company proposes to delete the referenced disclosure on page 1 of the Information Statement, as the Company does not believe such statement is required to be included in the Information Statement pursuant to Schedule 14C (or Schedule 14A, to the extent applicable to Schedule 14C) and does not believe such statement to be materially additive to the other disclosures contained in the Information Statement. If you have any questions or require additional information, please call the undersigned at (832) 538-0303 or email at mmize@halconresources.com. Sincerely, /s/ Mark J. Mize Mark J. Mize Executive Vice President, Chief Financial Officer and Treasurer 2