Correspondence 0001104659-23-031673 from Star Holdings (STHO) (CIK 0001953366) (STHO)
Star Holdings (STHO) (CIK 0001953366)
Date: March 13, 2023 · CIK: 0001953366 · Accession: 0001104659-23-031673
AI Filing Summary & Sentiment
File numbers found in text: 001-41572
Referenced dates: February 24, 2023
Letter
United States Securities and Exchange Commission Division of Corporation Finance Office of Real Estate and Construction Re: Star Holdings Amendment No. 2 to Registration Statement on Form 10 File No. 001-41572
Dear Messrs. Lewis, Telewicz, Regan and Link:
On behalf of Star Holdings ("Star Holdings,” the "Company" or "we"), we enclose for filing via EDGAR Amendment No. 2 to the Registration Statement on Form 10 ("Amendment No. 2"), including an amended information statement filed as Exhibit 99.1 to Amendment No. 2 (the "Information Statement"). Amendment No. 2 reflects: (i) the changes to the Information Statement described in the Company's response letter dated February 24, 2023; (ii) changes to the Information Statement relating to the distribution rate, record date and distribution date set for the Company's spin-off from iStar Inc.; and (iii) the Company's audited 2022 financial statements and related full year financial information.
If you have any questions regarding this filing, please do not hesitate to contact me at (212) 878-8526.
Sincerely,
/s/ Kathleen Werner
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Clifford Chance US LLP
March 13, 2023
Jeffrey Lewis
Robert Telewicz
Ruairi Regan
David Link
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Real Estate and Construction
100 F Street, NE
Washington, D.C. 20549
Re: Star Holdings
Amendment No. 2 to
Registration Statement on Form 10
File No. 001-41572
Dear Messrs. Lewis, Telewicz, Regan and Link:
On behalf of Star
Holdings ("Star Holdings,” the "Company" or "we"), we enclose for filing via EDGAR Amendment
No. 2 to the Registration Statement on Form 10 ("Amendment No. 2"), including an amended information
statement filed as Exhibit 99.1 to Amendment No. 2 (the "Information Statement"). Amendment No. 2 reflects: (i) the changes to the
Information Statement described in the Company's response letter dated February 24, 2023; (ii) changes to the Information
Statement relating to the distribution rate, record date and distribution date set for the Company's spin-off from iStar Inc.; and
(iii) the Company's audited 2022 financial statements and related full year financial information.
If you have any questions
regarding this filing, please do not hesitate to contact me at (212) 878-8526.
Sincerely,
/s/ Kathleen Werner
Kathleen Werner
cc:
Jay Sugarman, Chief Executive Officer, Star Holdings
Douglas B. Heitner, Chief Legal Officer, Star Holdings