SEC Comment Letter 0000000000-24-003237 to EchoStar CORP (SATS) (CIK 0001415404) (SATS)
EchoStar CORP (SATS) (CIK 0001415404)
Date: March 25, 2024 · CIK: 0001415404 · Accession: 0000000000-24-003237
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo March 25, 2024 Dean A. Mason Chief Legal Officer and Secretary EchoStar Corporation 100 Inverness Terrace East Englewood, CO 80112 Re:EchoStar Corporation SC TO-I/A filed March 22, 2024 File No. 005-83490 Dear Dean A. Mason: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Defined terms used herein have the same meaning as in your filing. Schedule TO-I/A filed March 22, 2024 Questions and Answers, page 6 1.We note your response to prior comment 1 and the fact that the first sentence of the answer to Question 24 has been revised from stating that an Eligible Employee’s trading plan “will be cancelled” to “may be cancelled” if an Eligible Employee elects to exchange an Eligible Option covered by a Rule 10b5-1 trading plan. Please explain to us the reason for this change, and please revise your disclosure to address specific uncertainties concerning whether a participant’s trading plan would be canceled if they elected to participate in the Exchange Offer. 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 Christina Chalk at 202- 551-3263.
FirstName LastNameDean A. Mason Comapany NameEchoStar Corporation March 25, 2024 Page 2 FirstName LastName Dean A. Mason EchoStar Corporation March 25, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Mergers & Acquisitions
Show Raw Text
United States securities and exchange commission logo
March 25, 2024
Dean A. Mason
Chief Legal Officer and Secretary
EchoStar Corporation
100 Inverness Terrace East
Englewood, CO 80112
Re:EchoStar Corporation
SC TO-I/A filed March 22, 2024
File No. 005-83490
Dear Dean A. Mason:
We have reviewed your filing and have the following comment. In our comment, we may
ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment by providing the requested information or advise us as
soon as possible when you will respond. If you do not believe our comment applies to your facts
and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Defined terms used herein have the same meaning as in your filing.
Schedule TO-I/A filed March 22, 2024
Questions and Answers, page 6
1.We note your response to prior comment 1 and the fact that the first sentence of the
answer to Question 24 has been revised from stating that an Eligible Employee’s trading
plan “will be cancelled” to “may be cancelled” if an Eligible Employee elects to exchange
an Eligible Option covered by a Rule 10b5-1 trading plan. Please explain to us the reason
for this change, and please revise your disclosure to address specific uncertainties
concerning whether a participant’s trading plan would be canceled if they elected to
participate in the Exchange Offer.
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 Christina Chalk at 202-
551-3263.
FirstName LastNameDean A. Mason
Comapany NameEchoStar Corporation
March 25, 2024 Page 2
FirstName LastName
Dean A. Mason
EchoStar Corporation
March 25, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions