SEC Comment Letter 0000000000-25-001465 to New Pluto Global, Inc. (CIK 0002041610) (PSKY)
New Pluto Global, Inc. (CIK 0002041610)
Date: Feb. 11, 2025 · CIK: 0002041610 · Accession: 0000000000-25-001465
AI Filing Summary & Sentiment
File numbers found in text: 333-282985
Letter
February 11, 2025 Naveen Chopra President and Chief Financial Officer New Pluto Global, Inc. c/o Paramount Global 1515 Broadway New York, New York 10036 Re:New Pluto Global, Inc. Amendment No. 3 to Registration Statement on Form S-4 Filed February 6, 2025 File No. 333-282985 Dear Naveen Chopra: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Amendment No. 3 to Registration Statement on Form S-4 The Transactions Litigation Relating to the Transactions, page 176 1.We note your disclosure here and throughout the registration statement related to the class action lawsuit alleging breaches of fiduciary duties for the alleged failure to sufficiently consider an alternate offer that is claimed to be superior to the Transactions. Please expand your disclosure to provide a full description of the factual basis alleged to underlie the proceedings derived from the complaint. Refer to Item 103 of Regulation S-K.
February 11, 2025 Page 2 Please contact Inessa Kessman at 202-551-3371 or Robert Littlepage at 202-551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact Alexandra Barone at 202-551-8816 or Matthew Derby at 202-551- 3334 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc:Hui Lin, Esq.
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February 11, 2025
Naveen Chopra
President and Chief Financial Officer
New Pluto Global, Inc.
c/o Paramount Global
1515 Broadway
New York, New York 10036
Re:New Pluto Global, Inc.
Amendment No. 3 to Registration Statement on Form S-4
Filed February 6, 2025
File No. 333-282985
Dear Naveen Chopra:
We have reviewed your amended registration statement and have the following
comment.
Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Amendment No. 3 to Registration Statement on Form S-4
The Transactions
Litigation Relating to the Transactions, page 176
1.We note your disclosure here and throughout the registration statement related to the
class action lawsuit alleging breaches of fiduciary duties for the alleged failure to
sufficiently consider an alternate offer that is claimed to be superior to the
Transactions. Please expand your disclosure to provide a full description of the factual
basis alleged to underlie the proceedings derived from the complaint. Refer to Item
103 of Regulation S-K.
February 11, 2025
Page 2
Please contact Inessa Kessman at 202-551-3371 or Robert Littlepage at 202-551-3361
if you have questions regarding comments on the financial statements and related
matters. Please contact Alexandra Barone at 202-551-8816 or Matthew Derby at 202-551-
3334 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Hui Lin, Esq.