TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo March 4, 2024 Gavriel Kahane Managing Partner Arkhouse Management Co. LP 106 W 56th Street, 17th Floor New York, NY 10019 Re: Arkhouse Management Co. LP Macy's, Inc. Soliciting Materials filed pursuant to Rule 14a-12 by Arkhouse Management Co. LP et al. Filed February 20, 2024 File No. 001-13536 Dear Gavriel Kahane: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Soliciting Materials filed pursuant to Rule 14a-12 Certain Information Concerning the Participants 1. In written soliciting materials used before a proxy statement is furnished, Rule 14a- 12(a)(1)(i) requires the soliciting party to include a description of each participant s direct and indirect interests in the solicitation, or a legend advising where that information can be found. Such interests are not limited to the participant s share ownership in the registrant. See the last sentence of CDI 132.03 under Proxy Rules and Schedules 14A/14C Compliance and Disclosure Interpretations (November 17, 2023). In future soliciting materials filed pursuant to Rule 14a-12, please include disclosure about the fact that Arkhouse Management recently made a proposal to acquire Macy s, which was rejected. We remind you that the filing persons are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Gavriel Kahane Arkhouse Management Co. LP March 4, 2024 Page 2 Please direct any questions to Brian Soares at 202-551-3690 or Christina Chalk at 202- 551-3263. FirstName LastNameGavriel Kahane Sincerely, Comapany NameArkhouse Management Co. LP Division of Corporation Finance March 4, 2024 Page 2 Office of Mergers & Acquisitions FirstName LastName