SEC Company Response from Hudson Pacific Properties, Inc. (HPP, HPP-PC) (CIK 0001482512) (HPP) — Jun 21, 2010
Hudson Pacific Properties, Inc. (HPP, HPP-PC) (CIK 0001482512)
Date: June 21, 2010 · CIK: 0001482512 · Accession: 0001193125-10-142917
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-164916
Letter
Acceleration Request
HUDSON PACIFIC PROPERTIES, INC.
11601 Wilshire Blvd., Suite 1600
Los Angeles, California 90025
June 21, 2010
VIA EDGAR AND FACSIMILE
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Tom Kluck, Branch Chief
Erin Martin, Attorney-Advisor
Cicely LaMothe, Accounting Branch Chief
Yolanda Crittendon, Staff Accountant
Re: Hudson Pacific Properties, Inc. Registration Statement on Form S-11, File No. 333-164916
Ladies and Gentlemen:
Pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, Hudson Pacific Properties, Inc. (the “Company”) hereby requests that the effective date of the above-referenced Registration Statement be accelerated to, and that such Registration Statement be declared effective on, Wednesday, June 23, 2010 at 4:00 p.m., Washington, D.C. time, or as soon thereafter as practicable, unless we or our outside counsel, Latham & Watkins LLP, request by telephone that such Registration Statement be declared effective at some other time.
The Company acknowledges the following:
•
should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
•
the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
•
the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
HUDSON PACIFIC PROPERTIES, INC.
By:
/s/ Victor J. Coleman
Name:
Victor J. Coleman
Title:
Chief Executive Officer
June 21, 2010
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Hudson Pacific Properties, Inc.
Registration Statement on Form S-11 (File No. 333-164916)
Ladies and Gentlemen:
As underwriters of the Company’s proposed public offering of up to 14,730,000 shares of common stock, we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness for 4:00 p.m. (NYT) on June 23, 2010, or as soon thereafter as is practicable.
Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, we wish to advise you that we have effected the following distribution of the Company’s Preliminary Prospectus dated June 14, 2010, through the date hereof:
Preliminary Prospectus dated June 14, 2010:
7,333 copies to prospective Underwriters, institutional investors, dealers and others
We were advised on June 21, 2010, by the Corporate Financing Department of the Financial Industry Regulatory Authority, Inc. that it has reviewed the above-captioned proposed offering and that it has determined to raise no objections with respect to the fairness and reasonableness of the underwriting terms and arrangements of the offering.
The undersigned advise that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934.
[signature page follows]
Very truly yours,
MERRILL LYNCH, PIERCE, FENNER & SMITH
Show Raw Text
CORRESP 1 filename1.htm Acceleration Request HUDSON PACIFIC PROPERTIES, INC. 11601 Wilshire Blvd., Suite 1600 Los Angeles, California 90025 June 21, 2010 VIA EDGAR AND FACSIMILE Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Tom Kluck, Branch Chief Erin Martin, Attorney-Advisor Cicely LaMothe, Accounting Branch Chief Yolanda Crittendon, Staff Accountant Re: Hudson Pacific Properties, Inc. Registration Statement on Form S-11, File No. 333-164916 Ladies and Gentlemen: Pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, Hudson Pacific Properties, Inc. (the “Company”) hereby requests that the effective date of the above-referenced Registration Statement be accelerated to, and that such Registration Statement be declared effective on, Wednesday, June 23, 2010 at 4:00 p.m., Washington, D.C. time, or as soon thereafter as practicable, unless we or our outside counsel, Latham & Watkins LLP, request by telephone that such Registration Statement be declared effective at some other time. The Company acknowledges the following: • should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; • the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and • the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Very truly yours, HUDSON PACIFIC PROPERTIES, INC. By: /s/ Victor J. Coleman Name: Victor J. Coleman Title: Chief Executive Officer June 21, 2010 Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Hudson Pacific Properties, Inc. Registration Statement on Form S-11 (File No. 333-164916) Ladies and Gentlemen: As underwriters of the Company’s proposed public offering of up to 14,730,000 shares of common stock, we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness for 4:00 p.m. (NYT) on June 23, 2010, or as soon thereafter as is practicable. Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, we wish to advise you that we have effected the following distribution of the Company’s Preliminary Prospectus dated June 14, 2010, through the date hereof: Preliminary Prospectus dated June 14, 2010: 7,333 copies to prospective Underwriters, institutional investors, dealers and others We were advised on June 21, 2010, by the Corporate Financing Department of the Financial Industry Regulatory Authority, Inc. that it has reviewed the above-captioned proposed offering and that it has determined to raise no objections with respect to the fairness and reasonableness of the underwriting terms and arrangements of the offering. The undersigned advise that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934. [signature page follows] Very truly yours, MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED BARCLAYS CAPITAL INC. MORGAN STANLEY & CO. INCORPORATED As Representatives of the several Underwriters By: BARCLAYS CAPITAL INC. By: /s/ Victoria Hale Victoria Hale Vice President