SEC Comment Letter for DigitalBridge Group, (DBRG) — Dec 3, 2019
DigitalBridge Group, Inc.
Date: Dec. 3, 2019 · CIK: 0001679688 · Accession: 0000000000-19-016040
AI Filing Summary & Sentiment
File numbers found in text: 001-37980
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE December 2, 2019 By E-Mail David W. Bonser , Esq. Hogan Lovells 555 Thirteenth Street NW Washington, DC 20004
Re: Colony Capital , Inc. Soliciting Materials filed pursuant to Rule 14a -12 Filed on November 26, 2019 File No. 001-37980
Dear Mr . Bonser :
We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may bett er understand your disclosure.
Please respond to this letter by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumsta nces or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to th ese comments , we may have additional comments.
Soliciting Materials 1. Each statement or assertion of opinion or belief must be clearly characterized as such, and a reasonable factual basis must exist for each such opinion or belief. Support for opinions or beliefs should be self -evident, disclosed in the proxy statement or prov ided to the staff on a supplemental basis. Provide support for the following statement s: That “the pivot to digital should also have a signifi cantly positive effect on the Company’s operating efficiency .” That “[t]here are a number of inaccuracies in Blackwells ’ press release …” 2. Please ensure that you remove doubt expressed by your use of the phrase “may be deemed” (“Important Additional Information ”) from whether the company, its directors and officers are participants in the solicitation . See instruction 3 to Item 4 in Schedule 14A.
David W. Bonser , Esq. Hogan Lovells December 2, 2019 Page 2
Please direct any questions to me at (202) 551 -3619.
Sincerely,
/s/ Daniel F. Duchovny
Daniel F. Duchovny
Special Counsel
Office of Mergers and Acquisitions
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
December 2, 2019
By E-Mail
David W. Bonser , Esq.
Hogan Lovells
555 Thirteenth Street NW
Washington, DC 20004
Re: Colony Capital , Inc.
Soliciting Materials filed pursuant to Rule 14a -12
Filed on November 26, 2019
File No. 001-37980
Dear Mr . Bonser :
We have reviewed your filing and have the following comments. In some of our comments,
we may ask you to provide us with information so we may bett er understand your disclosure.
Please respond to this letter by amending your filing, by providing the requested
information, or by advising us when you will provide the requested response. If you do not
believe our comments apply to your facts and circumsta nces or do not believe an amendment is
appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to th ese comments , we may have additional comments.
Soliciting Materials
1. Each statement or assertion of opinion or belief must be clearly characterized as such,
and a reasonable factual basis must exist for each such opinion or belief. Support for
opinions or beliefs should be self -evident, disclosed in the proxy statement or prov ided to
the staff on a supplemental basis. Provide support for the following statement s:
That “the pivot to digital should also have a signifi cantly positive effect on the
Company’s operating efficiency .”
That “[t]here are a number of inaccuracies in Blackwells ’ press release …”
2. Please ensure that you remove doubt expressed by your use of the phrase “may be
deemed” (“Important Additional Information ”) from whether the company, its directors
and officers are participants in the solicitation . See instruction 3 to Item 4 in Schedule
14A.
David W. Bonser , Esq.
Hogan Lovells
December 2, 2019
Page 2
Please direct any questions to me at (202) 551 -3619.
Sincerely,
/s/ Daniel F. Duchovny
Daniel F. Duchovny
Special Counsel
Office of Mergers and Acquisitions