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January 27, 2022
Andrew Freedman
Olshan Frome Wolosky LLP
1325 Avenue of the Americas
New York, NY
10019
Re:Huntsman CORP.
PREC14A filed January 20, 2022
Filed by Starboard Value LP, et. al.
File No. 001-32427
Dear Mr. Freedman:
            We have reviewed your filing 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 by providing the requested information or advise 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.
Preliminary Proxy Statement filed by Starboard Value LP
Cover Page
1.Please revise your disclosure to remove references to the annual meeting being held
virtually, as the company has not yet made any public statement in this respect.
Reasons for the Solicitation, page 8
2.Each statement or assertion of opinion or belief must be clearly characterized as such, and
a reasonable factual basis must exist for each such opinion or belief. Support for opinions
or beliefs should be self-evident, disclosed in the proxy statement or provided to the staff
on a supplemental basis. Thus, please provide us support for your disclosures that "[o]ver
the past seventeen years as a publicly-traded entity, the Company’s key management and
Board leadership roles have remained largely unchanged" (page 8) and that the company's
new "nominees were ...also supportive of straying from governance best practices" (page
13).

 FirstName LastNameAndrew Freedman
 Comapany Name1325 Avenue of the Americas
 January 27, 2022 Page 2
 FirstName LastName
Andrew Freedman
1325 Avenue of the Americas
January 27, 2022
Page 2
Proposal No. 1 Election of Directors, page 14
3.We note your references to your nominees' potential inability to "implement any actions
that they may believe are necessary to enhance stockholder value" given their minority
status. Please revise your disclosure to describe any plans you or your nominees have for
the company.
Quorum; Broker non-votes; Discretionary Voting, page 23
4.Please provide us your written analysis for your conclusion that brokers have
discretionary authority to vote on proposal 3.
            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 Daniel Duchovny at (202) 551-3619.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions