SecProbe.io

CORRESP
1
filename1.htm

CORRESP

 COLUMBIA SELIGMAN PREMIUM TECHNOLOGY GROWTH FUND, INC.

290 Congress Street

Boston, MA 02210

 August 26, 2024

 VIA EDGAR

 Ms. Yoon Choo

U.S. Securities and Exchange Commission

 Division of Investment
Management, Disclosure Review Office

 100 F Street, N.E.

Washington, D.C. 20549

 RE:

Columbia Seligman Premium Technology Growth Fund Inc.

 Registration Statement on Form N-2

File Nos. 333-280485 and 811-22328

 Dear Ms. Choo:

 This
letter responds to comments received from the staff (Staff) of the Securities and Exchange Commission on July 29, 2024 for the filing filed by and on behalf of Columbia Seligman Premium Technology Growth Fund, Inc. (the Registrant or the Fund).
Comments and responses are outlined below.

Comment 1:
 We note that the Registration Statement is missing information and exhibits and contains bracketed
disclosures. We may have comments on such portions when you complete them in any pre-effective amendment, on disclosures made in response to this letter, on information supplied supplementally, or on exhibits
filed in any pre-effective amendment. Please plan accordingly. Please note that, unless otherwise indicated, references to Items, Instructions and Guides are Items, Instructions and Guides to Form N-2.

Response:
 Understood.

Comment 2:
 Where a comment is made regarding disclosure in one location, it is applicable to all similar disclosure
appearing elsewhere in the Registration Statement. Please make all conforming changes.

Response:
 Conforming changes have been addressed as requested.

Comment 3:
 Please advise us if you have submitted or expect to submit any other exemptive applications or no-action requests in connection with the Registration Statement.

Response:
 We do not intend at this time to submit any other exemptive applications or no-action requests in connection with the Registration Statement.

Comment 4:
 Please supplementally confirm that all eXtensible Business Reporting Language elements will be tagged in
compliance with the requirements of Form N-2 per General Instruction 1.I and Rule 405 of Regulation S-T.

Response:
 Confirmed.

Comment 5:
 Please uncheck the box next to Section 8(c) on the facing sheet as the Registration Statement will become
effective pursuant to Section 8(a).

Response:
 The requested revision has been made.

PROSPECTUS COMMENTS:

Comment 6:
 On the prospectus cover, please revise disclosure regarding the description of “equity securities,”
which is used to describe the Fund’s investment in “technology and technology-related” securities, while “common stocks” is used to describe investments in options.

Response:
 The disclosure has been revised.

Comment 7:
 On the prospectus cover, please revise or clarify references to Prospectus Supplements since the registration
is not related to a shelf offering and otherwise consider noting that any prospectus supplements are those that the registrant may file in the future from time to time.

Response:
 The disclosure has been revised accordingly.

Comment 8:
 In the second paragraph on the cover of the prospectus, please delete the phrase about previously registered
securities.

Response:
 This disclosure has been deleted throughout the prospectus.

Comment 9:
 In the fourth paragraph on the cover of the prospectus, please briefly explain how the share price at which the
shares will be sold to the public will be determined (for example, by reference to net asset value). See Instruction 1 to Item 1.1(g).

Response:
 The disclosure has been revised accordingly.

Comment 10:
 In the fifth paragraph on the prospectus cover, please revise the sentence regarding inactive textual
references to carve out information that is explicitly incorporated by reference into the prospectus or Statement of Additional Information, or supplementally explain why it would not be appropriate to do so.

Response:
 The disclosure has been removed.

Comment 11:
 In the section Fees and Expenses of the Fund, please consider deleting the acquired fund fees and
expenses line from the table and any accompanying notes.

Response:
 The disclosure has been removed.

Comment 12:
 In the section Fees and Expenses of the Fund, please consider streamlining the note disclosure (for
example, by deleting note (a) and note (b) after the first sentence and moving that disclosure outside the summary section).

Response:
 The disclosure within note (a) and note (b) to the section Fees and Expenses of the
Fund has been revised. Much of the substance of note (a) appears in the “Capitalization” section and thus we have eliminated certain of the disclosure from note (a), and we removed disclosure from note (b) and
added it to the “More Information About the Fund – The Investment Manager” section.

Comment 13:
 Please disclose in an appropriate location in the prospectus how derivatives are valued for purposes of
calculating the Managed Assets on which the Fund pays fees to the advisor.

Response:
 The requested disclosure has been added to the More Information About the Fund – The Investment
Manager section.

Comment 14:
 In the Expense Examples table, please confirm that the amounts accurately reflect the Fund’s sales
load. See Instruction 11 to Item 3.1.

Response:
 The disclosure has been revised accordingly.

Comment 15:
 In the summary section, please remove or revise disclosure which notes that such disclosure is being
“qualified in its entirety” by other disclosure in the prospectus.

Response:
 The disclosure has been revised accordingly.

Comment 16:
 Under The Fund’s Investment Strategy, please disclose the specific types of equity securities in
which the Fund invests. In this regard, the Fund’s latest N-PORT reflects 97.6% investment in common stocks.

Response:
 The disclosure has been revised accordingly.

Comment 17:
 Under The Fund’s Investment Strategy with respect to “technology and technology-related
companies,” please disclose the managers’ criteria for determining whether a company falls under the definition of a “technology company” and the meaning of “technology-related company” to clarify such company’s
relationship to technology companies.

Response:
 The Fund has revised the disclosure within The Fund’s Investment Strategy in the Summary
section and the More Information About the Fund – Investment Objective and Polices section to add the requested disclosure.

Comment 18:
 Under The Fund’s Investment Strategy, please consider disclosing the sectors or industries in which
the Fund’s investments are concentrated. In this regard, we note that the latest N-PORT filing reflects 66.7% of the Fund’s investments are in information technology stocks and within that category
33.6% are in semiconductors and semiconductor equipment.

Response:
 The Fund’s Investment Strategy has been revised to include the Fund’s policy to
concentrate its investments in technology and technology-related stocks, which means that the Fund invests at least 25% of the value of its Managed Assets in technology and technology-related stocks, and that the Fund tends to focus its investments
on companies in the information technology sector and semiconductors and semiconductor equipment industry.

Comment 19:
 In an appropriate section of the prospectus, please provide a brief description of the S&P North American
Technology Sector Index®.

Response:
 The requested disclosure has been added to the More Information About the Fund – Investment
Objective and Policies section.

Comment 20:
 Under The Fund’s Investment Strategy, please revise the description of the Nasdaq 100 Index to
conform to the description on Nasdaq’s site. Also, please disclose the name of the specific ETF that the Fund may use as a reference, or if there is no specific ETF, change “its” to “an.”

Response:
 The disclosure has been revised accordingly.

Comment 21:
 Under The Fund’s Investment Manager, please expand the description of the managers’ functions
to include day-to-day operations of the Fund, including determining which securities the Fund will buy and sell and executing portfolio transactions.

Response:
 The disclosure has been revised accordingly.

Comment 22:
 In the Prospectus Summary, please consider adding cross-references in The Fund’s Investment
Manager, The Fund Offering, Distributions, Dividend Reinvestment Plan, and Stock Repurchase Program, to additional disclosure elsewhere in the prospectus.

Response:
 The disclosure has been revised accordingly.

Comment 23:
 Please consider describing other principal service providers in the Summary of the Fund section.

Response:
 A description of the distributor of the Fund’s shares of common stock offered under the Fund’s
prospectus with respect to an at-the-market offering of such shares has been added to the Summary of the Fund section.

Comment 24:
 The discussion of the Fund’s distribution policy only appears under the Summary of the Fund –
Prospectus Summary – Distributions. Since the disclosure in the summary is intended to provide a summary of the more complete discussion, please add additional disclosure and a cross-reference later in the prospectus.

Response:
 The Summary of the Fund – Prospectus Summary – Distributions section and
Distributions and Taxes section have been revised to address the Staff’s comment.

Comment 25:
 The discussion of the Fund’s distribution policy only appears under the Summary of the Fund –
Prospectus Summary – Distributions. Since the disclosure in the summary is intended to provide a summary of the more complete discussion, please add additional disclosure and a cross-reference later in the prospectus. Also,
the term “equity-related securities” is used in this section but does not appear elsewhere in the prospectus. If equity-related securities are principal investments of the Fund, please add a discussion to The Fund’s
Investment Strategy section.

Response:
 As noted in the response to comment 24 above, the Summary of the Fund – Prospectus
Summary – Distributions section and Distributions and Taxes section have been revised to address the Staff’s comments 24 and 25.

Comment 26:
 Disclosure concerning return of capital appears in the Summary of the Fund – Prospectus
Summary – Distributions. Please add in an appropriate location in the prospectus that any capital return to stockholders through distributions will be distributed after the payment of Fund fees and expenses.

Response:
 The requested disclosure has been added.

Comment 27:
 In reference to the last sentence of the second paragraph appearing under Summary of the Fund –
Prospectus Summary – Distributions, please consider adding a cross-reference to the excise tax discussion later in the prospectus.

Response:
 The second and follow-on paragraphs under Summary of the
Fund – Prospectus Summary – Distributions have been relocated to later in the Prospectus within the Distributions and Taxes section and, as such, a cross-reference to the Tax section is unnecessary.

Comment 28:
 Per plain English requirements, please revise the disclosure appearing under Summary of the Fund –
Prospectus Summary – Stock Repurchase Program to simply and clearly state when the Fund may repurchase Common Shares. In particular, explain whether “attributable to distributions” includes premiums received from writing
options contracts. Alternatively, please add an example.

Response:
 The disclosure has been revised accordingly. Please note that “attributable to distributions”
does not include premiums received from writing options contracts.

Comment 29:
 A summary section, if provided, should provide a summary of material information. Please summarize the material
risks under Summary of the Fund – Prospectus Summary – Risks and not a

cross-reference to the More Information About the Fund – Principal Risks section. Please note that the risks should summarize and not simply repeat the main risks. See Instructions to
Item 3.2.

Response:
 The disclosure under Summary of the Fund – Prospectus Summary has been revised
accordingly.

Comment 30:
 Per General Instruction 2 of Item 4, please disclose under Financial Highlights and Investment
Performance, that the auditor’s report is contained elsewhere in the registration statement and specify its location.

Response:
 The disclosure has been revised accordingly.

Comment 31:
 Under the section Use of Proceeds, please consider whether the second paragraph that starts with
“Sales of Common Shares” is appropriate under this section.

Response:
 The second paragraph under the section Use of Proceeds has been deleted, but certain sentences
thereof have been added to the Plan of Distribution of Common Shares section.

Comment 32:
 Under the section Plan of Distribution of Common Shares per Item 5.6, please disclose the date by
which investors must pay for common shares.

Response:
 The requested disclosure has been added.

Comment 33:
 Please confirm if the last sentence of the fifth paragraph under More Information About the Fund
– Investment Objective and Policies is a principal investment strategy. If so, add corresponding disclosure to the Summary section. If not, please clearly state that this is not a principal investment strategy.

Response:
 The last sentence of the fifth paragraph under More Information About the Fund – Investment
Objective and Policies is a principal investment strategy of the Fund and disclosure has been added to the Summary section.

Comment 34:
 Please consider whether the disclosure of the Fund investing up to 20% in debt securities and 25% in
foreign securities constitutes a principal investment strategy that should be disclosed in the Prospectus Summary – The Fund’s Investment Strategy.

Response:
 The Fund’s policy of investing up to 20% in debt securities and 25% in foreign securities are not
principal investment strategies of the Fund, and therefore need not be disclosed in the Prospectus Summary – The Fund’s Investment Strategy.

Comment 35:
 There are numerous risk factors that discuss risks of investments that are not disclosed in the
investment strategy discussion in the summary section, including convertible securities risk, foreign securities risk, small- and mid-cap stock risk, and Rule 144A and other exempted securities risk. If
these are material risks of the Fund, please revise The Fund’s Investment Strategy in the Prospectus Summary section to cover these investments. If not, please revise the investment strategy and the Principal Risks
discussion in the More Information About the Fund section to indicate clearly that these are not principal investments or principal risks of the Fund.

Response:
 The Fund has removed from its investment strategy discussion mentions of investing in convertible
securities and Rule 144A and other exempted securities, and has correspondingly removed references from the Prospectus to the risks of same. The Fund has added investing in small-, mid- and large-cap stocks and investing in foreign stocks to The Fund’s Investment Strategy in the Prospectus Summary section.

Comment 36:
 Please consider consolidating the section More Information About the Fund – Transactions
in Derivatives with Derivatives Risks under More Information About the Fund – Principal Risks.

Response:
 The disclosure in the More Information About the Fund – Transactions in Derivatives section
is included to provide investors with additional information about the Fund’s ability to enter into certain derivatives transactions, including specific types of derivatives that are not individually expected to be a principal investment
strategy. This disclosure will continue to be included in the prospectus.

Comment 37:
 The fourth sentence of the second paragraph under the section Transactions in Derivatives, please
add a cross reference to the relevant tax discussion.

Response:
 The requested disclosure has been added.

Comment 38:
 Regarding the third sentence in the second paragraph under Management of the Fun