TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo June 23, 2022 Richard K. Coleman, Jr. Chief Executive Officer Star Equity Holdings, Inc. 53 Forest Ave., Suite 101 Old Greenwich, CT 06870 Re: Star Equity Holdings, Inc. Registration Statement on Form S-3 Filed June 21, 2022 File No. 333-265737 Dear Mr. Coleman: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Joshua Gorsky at 202-551-7836 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Claudia B. Dub n, Esq.