Correspondence 0001493152-24-023281 from Saltchuk Resources, Inc. (CIK 0001806446)
Saltchuk Resources, Inc. (CIK 0001806446)
Date: June 10, 2024 · CIK: 0001806446 · Accession: 0001493152-24-023281
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CORRESP
1
filename1.htm
June
10, 2024
Christopher
J. Voss
Partner
CJ.Voss@klgates.com
United
States Securities and Exchange Commission
T
+1 206 370 7609
Division
of Corporate Finance
F
+1 206 370 6172
100
F Street N.E.
Washington,
DC 20549
Re:
Saltchuk Resources, Inc. – Tender Offer Statement on
Schedule TO
Ladies
and Gentlemen:
On
behalf of Saltchuk Resources, Inc., and its wholly-owned subsidiary Seahawk MergeCo., Inc. (collectively, “Saltchuk”), and
pursuant to the Securities Exchange Act of 1934, as amended (the “Exchange Act”), and the rules and regulations of the Securities
and Exchange Commission thereunder, accompanying this letter for filing under the Exchange Act is the Tender Offer Statement on Schedule
TO relating to Saltchuk’s offer to purchase all of the issued and outstanding shares of Class A common stock of Overseas Shipholding
Group, Inc. (the “Company”) for $8.50 per share in cash, upon the terms and subject to the conditions described in
the Offer to Purchase, dated June 10, 2024, filed as Exhibit a(1)(A) to the Schedule TO.
The
filing fee of $77,362.04 has been sent by wire transfer to the Commission’s account at US Bank. The Company’s CIK number
is 0000075208.
On
May 2, 2024, the undersigned spoke with Mr. Perry Hindin, Special Counsel in the SEC’s Office of Mergers and Acquisitions of the
Division of Corporation Finance, on a “no names” basis concerning certain aspects of the transactions described in the Schedule
TO. During the call, Mr. Hindin recommended that the Schedule TO be accompanied by a letter of transmittal referencing the conversation.
Should
you have any questions with respect to this filing, please call the undersigned at 206-370-7609 or Michelle McCreery at 412-355-8317.
Very
truly yours,
/s/
Christopher J. Voss
Christopher
J. Voss
K&L
Gates LLP
925
Fourth Avenue Suite 2900 Seattle WA 98104-1158
T
+1 206 623 7580 F +1 206 623 7022 klgates.com