Correspondence 0001104659-22-127613 from Star Holdings (STHO) (CIK 0001953366) (STHO)
Star Holdings (STHO) (CIK 0001953366)
Date: Dec. 16, 2022 · CIK: 0001953366 · Accession: 0001104659-22-127613
AI Filing Summary & Sentiment
Letter
CLIFFORD CHANCE US LLP
31 West 52nd Street
New York, NY 10019-6131
Tel +1 212 878 8000
Fax +1 212 878 8375
www.cliffordchance.com
December 16, 2022
Via EDGAR Filing
Re: Star Holdings Registration Statement on Form 10
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Ladies and Gentlemen:
On behalf of Star Holdings, a Maryland statutory trust, we hereby transmit for filing under the Securities Exchange Act of 1934, as amended, a registration statement on Form 10 relating to the registration of the common shares of beneficial interest of Star Holdings, a Maryland statutory trust. Star Holdings is currently a wholly-owned subsidiary of iStar Inc., a Maryland corporation. Star Holdings has been formed to own and manage certain assets of iStar that will be separated from iStar prior to the closing of the previously-announced all-stock merger between iStar and Safehold Inc., a Maryland corporation, pursuant to the Agreement and Plan of Merger, dated August 10, 2022. iStar intends to distribute all of its equity interests in Star Holdings to the stockholders of iStar prior to the closing of the merger.
For the information of the staff of the Securities and Exchange Commission, we have also transmitted for filing today a Form S-4 registration statement for the registration of shares of common stock of iStar that will be issued to the stockholders of Safehold in connection with the merger.
If you have any questions about the above-referenced Form 10 Registration Statement, please contact Kathleen L. Werner of Clifford Chance US LLP, counsel to Star Holdings, at (212) 878-8526.
Very truly yours,
/s/ Kathleen L. Werner
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CLIFFORD CHANCE US LLP
31 West 52nd Street
New York, NY 10019-6131
Tel +1 212 878 8000
Fax +1 212 878 8375
www.cliffordchance.com
December 16, 2022
Via EDGAR Filing
Re: Star
Holdings Registration Statement on Form 10
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Ladies and Gentlemen:
On behalf of Star Holdings,
a Maryland statutory trust, we hereby transmit for filing under the Securities Exchange Act of 1934, as amended, a registration statement
on Form 10 relating to the registration of the common shares of beneficial interest of Star Holdings, a Maryland statutory trust. Star
Holdings is currently a wholly-owned subsidiary of iStar Inc., a Maryland corporation. Star Holdings has been formed to own and manage
certain assets of iStar that will be separated from iStar prior to the closing of the previously-announced all-stock merger between iStar
and Safehold Inc., a Maryland corporation, pursuant to the Agreement and Plan of Merger, dated August 10, 2022. iStar intends to distribute
all of its equity interests in Star Holdings to the stockholders of iStar prior to the closing of the merger.
For the information of the staff
of the Securities and Exchange Commission, we have also transmitted for filing today a Form S-4 registration statement for the registration
of shares of common stock of iStar that will be issued to the stockholders of Safehold in connection with the merger.
If you have any questions about
the above-referenced Form 10 Registration Statement, please contact Kathleen L. Werner of Clifford Chance US LLP, counsel to Star Holdings,
at (212) 878-8526.
Very truly yours,
/s/ Kathleen L. Werner
Kathleen L. Werner, Esq.
Clifford Chance US LLP