SEC Company Response from DULUTH HOLDINGS INC. (DLTH) (CIK 0001649744) (DLTH) — Nov 9, 2015
DULUTH HOLDINGS INC. (DLTH) (CIK 0001649744)
Date: Nov. 9, 2015 · CIK: 0001649744 · Accession: 0001193125-15-371175
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-207300
Letter
780 NORTH WATER STREET
MILWAUKEE, WISCONSIN 53202-3590
TEL • 414.273.3500 FAX • 414.273.5198
www • GKLAW.COM
November 9, 2015
VIA EDGAR
John Reynolds
Assistant Director
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
RE: Duluth Holdings Inc.
Registration Statement on Form S-1
File No. 333-207300
Ladies and Gentlemen:
On behalf of Duluth Holdings Inc. (the “Company”), we submit this letter to provide information requested by the staff of the Securities and Exchange Commission (the “Staff”) in connection with its review of the Company’s Registration Statement on Form S-1 (Registration No. 333-207300) initially filed with the Commission on October 6, 2015 (the “Registration Statement”), as amended by Amendment No. 1 to the Registration Statement filed with the Commission on October 13, 2015.
The Staff requested the Company update its Use of Proceeds sections on page 36 of the Registration Statement to provide greater detail of the contingencies and alternatives to the Company’s use of proceeds based upon such contingencies and/or alternatives. The Company provided the Staff with draft language of its Use of Proceeds section to review, which is attached hereto as Exhibit A.
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Should the staff have additional questions regarding the foregoing, please do not hesitate to contact the undersigned at (414) 287-9258.
OFFICES IN MILWAUKEE, MADISON, WAUKESHA, GREEN BAY AND APPLETON, WISCONSIN AND WASHINGTON, D.C.
GODFREY & KAHN, S.C. IS A MEMBER OF TERRALEX,® A WORLDWIDE NETWORK OF INDEPENDENT LAW FIRMS.
Securities and Exchange Commission
November 9, 2015
Page 2
Very truly yours,
GODFREY & KAHN, S.C.
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CORRESP 1 filename1.htm CORRESP 780 NORTH WATER STREET MILWAUKEE, WISCONSIN 53202-3590 TEL • 414.273.3500 FAX • 414.273.5198 www • GKLAW.COM November 9, 2015 VIA EDGAR John Reynolds Assistant Director Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, DC 20549 RE: Duluth Holdings Inc. Registration Statement on Form S-1 File No. 333-207300 Ladies and Gentlemen: On behalf of Duluth Holdings Inc. (the “Company”), we submit this letter to provide information requested by the staff of the Securities and Exchange Commission (the “Staff”) in connection with its review of the Company’s Registration Statement on Form S-1 (Registration No. 333-207300) initially filed with the Commission on October 6, 2015 (the “Registration Statement”), as amended by Amendment No. 1 to the Registration Statement filed with the Commission on October 13, 2015. The Staff requested the Company update its Use of Proceeds sections on page 36 of the Registration Statement to provide greater detail of the contingencies and alternatives to the Company’s use of proceeds based upon such contingencies and/or alternatives. The Company provided the Staff with draft language of its Use of Proceeds section to review, which is attached hereto as Exhibit A. ******** Should the staff have additional questions regarding the foregoing, please do not hesitate to contact the undersigned at (414) 287-9258. OFFICES IN MILWAUKEE, MADISON, WAUKESHA, GREEN BAY AND APPLETON, WISCONSIN AND WASHINGTON, D.C. GODFREY & KAHN, S.C. IS A MEMBER OF TERRALEX,® A WORLDWIDE NETWORK OF INDEPENDENT LAW FIRMS. Securities and Exchange Commission November 9, 2015 Page 2 Very truly yours, GODFREY & KAHN, S.C. /s/ Dennis F. Connolly Dennis F. Connolly Securities and Exchange Commission November 9, 2015 Page 3 Exhibit A