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SEC Comment Letter for CMB.TECH NV (CMBT) (CIK 0001604481) (CMBT) — Sep 24, 2014

CMB.TECH NV (CMBT) (CIK 0001604481)
Date: Sept. 24, 2014 · CIK: 0001604481 · Accession: 0000000000-14-047922

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
Sept. 24, 2014
Author
/s/ Susan Block
Form
UPLOAD
Company
CMB.TECH NV (CMBT) (CIK 0001604481)

Letter

September 24 , 2014 Via E -mail Patrick Rodgers Chief Executive Officer Euronav NV De Gerlachekaai 20 2000 Antwerpen Belgium

Re: Euronav NV Registration Statement on Form F-4 Filed September 8 , 2014 File No. 333 -198626

Dear Mr. Rodgers :

We have reviewed your registration statement and have the following addition al 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 this letter by amending your registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please t ell us why in your response.

After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments .

Exhibit 23.6

1. Please revise this consent to refer to the section in the prospectus entitled “Overview of the Offshore Oil and Gas Industry” as opposed to “Overview of the Oil and Gas Industry” and re -file.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible f or the accuracy and adequacy of the disclosures they have made.

Patrick Rodgers Euronav NV September 24 , 2014 Page 2

Notwithstanding our comments, in the event you request acceleration of the effective date of the pending regist ration statement please provide a written statement from the company acknowled ging that:

 should 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.

Please refer to Rules 460 and 461 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the securities specified in the above registration statement. Please allow adequate time for us to review any amendment prior to the requested effective date o f the registration statement.

Please contact Ada D. Sarmento at (202) 551 -3798 or me at (202) 551 -3210 with any other questions.

Sincerely,
/s/ Susan Block

Show Raw Text
September 24 , 2014

Via E -mail
Patrick Rodgers
Chief Executive Officer
Euronav NV
De Gerlachekaai  20
2000 Antwerpen
Belgium

Re: Euronav NV
Registration Statement on Form F-4
Filed  September 8 , 2014
  File No. 333 -198626

Dear Mr. Rodgers :

We have reviewed your registration statement and have the following addition al
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 this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please t ell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments .

Exhibit 23.6

1. Please revise this consent to refer to the section in the prospectus entitled “Overview of
the Offshore Oil and Gas Industry” as opposed to “Overview of the Oil and Gas
Industry” and re -file.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to  be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible f or the accuracy
and adequacy of the disclosures they have made.

Patrick Rodgers
Euronav NV
September 24 , 2014
Page 2

 Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending regist ration statement please provide  a written statement from the company
acknowled ging that:

 should 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.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of  1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date o f the
registration statement.

Please contact Ada D. Sarmento at (202) 551 -3798  or me at (202) 551 -3210  with any
other questions.

Sincerely,

 /s/ Susan Block

Susan Block
Attorney -Advisor

cc: Via E-mail
 Gary J. Wolfe , Esq.