Correspondence 0001104659-23-034782 from Star Holdings (STHO) (CIK 0001953366) (STHO)

Star Holdings (STHO) (CIK 0001953366)
Date: March 21, 2023 · CIK: 0001953366 · Accession: 0001104659-23-034782

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AI Filing Summary & Sentiment

File numbers found in text: 001-41572

Date

March 21, 2023

Author

Chief Legal Officer

Form

CORRESP

Company

Star Holdings (STHO) (CIK 0001953366)

Letter

Division of Corporation Finance Attn: Ruairi Regan Real Estate & Construction Star Holdings Registration Statement on Form 10 (File No. 001-41572)

Dear Mr. Regan:

In accordance with Rule 12d1-2 promulgated under the Securities Exchange Act of 1934, as amended, Star Holdings hereby respectfully requests that the effective date of its Registration Statement on Form 10 (File No. 001-41572) (the "Registration Statement") be accelerated by the U.S, Securities and Exchange Commission to 4:30 p.m., New York City time, on March 22, 2023, or as soon thereafter as practicable.

It would be appreciated if, as soon as the Registration Statement is declared effective, you would so inform the undersigned at (212) 930-9485 or Kathleen Werner of Clifford Chance US LLP at (212) 878-8526.

Yours truly,

STAR HOLDINGS

/s/ Douglas Heitner

Douglas Heitner

Chief Legal Officer

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CORRESP
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STAR HOLDINGS

1114 Avenue of the Americas

39th Floor

New York, New York 10036

March 21, 2023

BY EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn:        Ruairi
Regan

                   Real Estate & Construction

Star Holdings

Registration Statement on Form 10 (File
No. 001-41572)

Dear Mr. Regan:

In accordance with
Rule 12d1-2 promulgated under the Securities Exchange Act of 1934, as amended, Star Holdings hereby respectfully requests that
the effective date of its Registration Statement on Form 10 (File No. 001-41572) (the "Registration
Statement") be accelerated by the U.S, Securities and Exchange Commission to
4:30 p.m., New York City time, on March 22,
2023, or as soon thereafter as practicable.

It would be appreciated if,
as soon as the Registration Statement is declared effective, you would so inform the undersigned at (212) 930-9485 or Kathleen Werner
of Clifford Chance US LLP at (212) 878-8526.

    Yours truly,

    STAR HOLDINGS

    /s/ Douglas Heitner

    Douglas Heitner

    Chief Legal Officer

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