SEC Comment Letter 0000000000-24-013322 to Anterix Inc. (ATEX) (CIK 0001304492) (ATEX)
Anterix Inc. (ATEX) (CIK 0001304492)
Date: Dec. 3, 2024 · CIK: 0001304492 · Accession: 0000000000-24-013322
AI Filing Summary & Sentiment
Letter
December 3, 2024 William Heard Manager Heard Capital LLC 3 Garret Mountain Plaza, Suite 401 Woodland Park, NJ 07424 Re:Heard Capital LLC Anterix Inc. Schedule 13D Filed by Heard Capital LLC et al. Filed July 29, 2024 File No. 005-88631 Dear William Heard: We have conducted a limited review of the above-captioned filing and have the following comments . Please respond to this letter by amending the filing or by providing the requested information. If you do not believe our comments apply to your facts and circumstances or that an amendment is appropriate , please advise us why in a response letter. After reviewing any amendment to the filing and any information provided in response to these comments, we may have additional comments. Schedule 13D Filed July 29, 2024 General 1.We note the date of the event reported as requiring the filing of the Statement was May 28, 2024. Rule 13d-1(a) of Regulation 13D-G requires the filing of a Schedule 13D within five business days after the date beneficial ownership of more than five percent of a class of equity securities specified in Rule 13d-1(i)(1) was acquired. Based on the May 28, 2024 event date, the Schedule 13D submitted on July 29, 2024 was not timely filed. Please advise us why the Schedule 13D was not filed within the required five business days after the date of the acquisition. Unlike the above-captioned Schedule 13D, we noticed that the Schedule 13G filed on February 13, 2023 by Heard Capital LLC did not include Heard Investment Manager LLC, the William E. Heard Declaration of Trust, or William Heard as reporting persons. Based on the disclosure provided in the referenced Schedule 13D, however, 2.
December 3, 2024 Page 2 it appears that those newly identified reporting persons already had beneficial ownership over the securities earlier reported in the associated Schedule 13G as of the date of the event reported as requiring the filing of that Schedule 13G. Please advise us why those reporting persons were not included in that Schedule 13G. 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. Please direct any questions to Brian Soares at 202-551-3690 or Nicholas Panos at 202-551-3266. Sincerely, Division of Corporation Finance Office of Mergers & Acquisitions
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December 3, 2024
William Heard
Manager
Heard Capital LLC
3 Garret Mountain Plaza, Suite 401
Woodland Park, NJ 07424
Re:Heard Capital LLC
Anterix Inc.
Schedule 13D Filed by Heard Capital LLC et al.
Filed July 29, 2024
File No. 005-88631
Dear William Heard:
We have conducted a limited review of the above-captioned filing and have the
following comments .
Please respond to this letter by amending the filing or by providing the requested
information. If you do not believe our comments apply to your facts and circumstances or
that an amendment is appropriate , please advise us why in a response letter.
After reviewing any amendment to the filing and any information provided in
response to these comments, we may have additional comments.
Schedule 13D Filed July 29, 2024
General
1.We note the date of the event reported as requiring the filing of the Statement was
May 28, 2024. Rule 13d-1(a) of Regulation 13D-G requires the filing of a Schedule
13D within five business days after the date beneficial ownership of more than five
percent of a class of equity securities specified in Rule 13d-1(i)(1) was acquired.
Based on the May 28, 2024 event date, the Schedule 13D submitted on July 29, 2024
was not timely filed. Please advise us why the Schedule 13D was not filed within the
required five business days after the date of the acquisition.
Unlike the above-captioned Schedule 13D, we noticed that the Schedule 13G filed on
February 13, 2023 by Heard Capital LLC did not include Heard Investment Manager
LLC, the William E. Heard Declaration of Trust, or William Heard as reporting
persons. Based on the disclosure provided in the referenced Schedule 13D, however, 2.
December 3, 2024
Page 2
it appears that those newly identified reporting persons already had beneficial
ownership over the securities earlier reported in the associated Schedule 13G as of
the date of the event reported as requiring the filing of that Schedule 13G. Please
advise us why those reporting persons were not included in that Schedule 13G.
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.
Please direct any questions to Brian Soares at 202-551-3690 or Nicholas Panos at
202-551-3266.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions