SEC Comment Letter for Atlanticus Holdings Corp (ATLC, ATLCL, ATLCP, ATLCZ) (CIK 0001464343) (ATLC) — Jul 22, 2014
Atlanticus Holdings Corp (ATLC, ATLCL, ATLCP, ATLCZ) (CIK 0001464343)
Date: July 22, 2014 · CIK: 0001464343 · Accession: 0000000000-14-037001
AI Filing Summary & Sentiment
Referenced dates: July 17, 2014, July 17, 2014
Letter
July 22, 2014 Via E -mail W. Brinkley Dickerson, Jr. Troutman Sanders LLP 600 Peachtree Street, NE, Suite 5200 Atlanta, GA 30308
Re: Atlanticus Holdings Corporation Amendment No. 1 to Schedule TO -I Filed July 15 , 2014 File No. 005 -85199
Dear Mr. Dickerson :
We have review ed the above -referenced filing and the response letter dated July 17, 2014.
1. We have consider ed the a nalysis submitted in support of the positions expressed in the above -captioned response letter dated July 17, 2014. Without expressing an opinion as to whether or not the amended tender offer is compliant with the applicable tender offer provisions identified in that response letter, or agree ing or disagreeing with any or the analysis and positions set forth therein , particularly with respect to Atlanticus’ use of a novel pricing mechanism, we do not have any further comments at this time. Please note, however, that notwithstan ding this decision to not issue additional comments at present, all persons who are by statute and rule responsible for the adequacy and accuracy of the disclosure continue to remain responsi ble for ensuring compliance with Section 14(e) of the Exchange Act, Regulation 14(e) and Rule 13e -4.
Please contact Nicholas Panos , Senior Special Counsel, at (202) 551 -3266 or me at (202) 551-3641 with any questions.
Sincerely,
/s/ Geoff Kruczek
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July 22, 2014 Via E -mail W. Brinkley Dickerson, Jr. Troutman Sanders LLP 600 Peachtree Street, NE, Suite 5200 Atlanta, GA 30308 Re: Atlanticus Holdings Corporation Amendment No. 1 to Schedule TO -I Filed July 15 , 2014 File No. 005 -85199 Dear Mr. Dickerson : We have review ed the above -referenced filing and the response letter dated July 17, 2014. 1. We have consider ed the a nalysis submitted in support of the positions expressed in the above -captioned response letter dated July 17, 2014. Without expressing an opinion as to whether or not the amended tender offer is compliant with the applicable tender offer provisions identified in that response letter, or agree ing or disagreeing with any or the analysis and positions set forth therein , particularly with respect to Atlanticus’ use of a novel pricing mechanism, we do not have any further comments at this time. Please note, however, that notwithstan ding this decision to not issue additional comments at present, all persons who are by statute and rule responsible for the adequacy and accuracy of the disclosure continue to remain responsi ble for ensuring compliance with Section 14(e) of the Exchange Act, Regulation 14(e) and Rule 13e -4. Please contact Nicholas Panos , Senior Special Counsel, at (202) 551 -3266 or me at (202) 551-3641 with any questions. Sincerely, /s/ Geoff Kruczek Geoff Kruczek Attorney -Advisor Office of Mergers & Acquisitions