0001504304-15-000027.txt : 20150529
0001504304-15-000027.hdr.sgml : 20150529
20150318090322
ACCESSION NUMBER: 0001504304-15-000027
CONFORMED SUBMISSION TYPE: CORRESP
PUBLIC DOCUMENT COUNT: 1
FILED AS OF DATE: 20150318
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: Bulldog Investors, LLC
CENTRAL INDEX KEY: 0001504304
IRS NUMBER: 270926182
STATE OF INCORPORATION: DE
FISCAL YEAR END: 1231
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: PARK 80 WEST - PLAZA TWO
STREET 2: 250 PEHLE AVE. SUITE 708
CITY: SADDLE BROOK
STATE: NJ
ZIP: 07663
BUSINESS PHONE: 201 556-0092
MAIL ADDRESS:
STREET 1: PARK 80 WEST - PLAZA TWO
STREET 2: 250 PEHLE AVE. SUITE 708
CITY: SADDLE BROOK
STATE: NJ
ZIP: 07663
FORMER COMPANY:
FORMER CONFORMED NAME: Brooklyn Capital Management LLC
DATE OF NAME CHANGE: 20101026
CORRESP
1
filename1.txt
Bulldog Investors, LLC
250 Pehle Avenue, Suite 708, Saddle Brook, NJ 07663
(201) 881-7111 // pgoldstein@bulldoginvestors.com
March 17, 2015
Jay Williamson
Division of Investment Management
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
LMP Real Estate Income Fund Inc. (the "Fund")
Contested Proxy Solicitation
Dear Mr. Williamson:
This is in response to your comments regarding our proxy solicitation
for the Fund. As discussed below, we have carefully considered each of
your comments and, as appropriate, intend to revise our definitive
soliciting material to reflect them.
.. Please be advised that our policy is to respectfully decline to
agree to waive our right to present a zealous defense in connection
with any legal proceeding.
.. We affirm that in our definitive soliciting material, we intend to
fill in any blanks in our preliminary filing with the most recent data
available to us.
.. We understand and intend to comply with Rule 14a-6(b) and (c) by filing
the appropriate documents on EDGAR.
.. We have not determined whether or how we will use the internet to
solicit.
.. We have had no substantive communications with management of the Fund.
.. The means stated to revoke our proxy are exclusive.
With respect to the paragraph (b)(3)(ii) of item 22 of "Schedule 14A.
Information required in proxy statement," there are no arrangements or
understanding between any nominee and any other person. Mr. Dakos was
selected as a nominee because he is a principal of Bulldog Investors.
The other nominees were selected because they are known to Bulldog
Investors.
.. We applied the SEC definition of "participant" to determine the
participants in our solicitation. However, we believe that the SEC's
definition is overbroad and thus misleading because a reasonable person
would incorrectly think that every person who is covered by that
definition will actively participate in the solicitation of proxies.
By analogy, a reasonable person would not label a person that merely
signs a petition to have a candidate for political office placed on the
official ballot as a "participant" in the candidate's election campaign.
.. We will revise the cover page of our definitive filing to identify each
"true" participant in the solicitation.
Please contact me if you wish to discuss this matter.
Very truly yours,
/S/ Phillip Goldstein
Phillip Goldstein
Member