0000950170-23-049233.txt : 20231024 0000950170-23-049233.hdr.sgml : 20231024 20230921173530 ACCESSION NUMBER: 0000950170-23-049233 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20230921 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Heritage Global Inc. CENTRAL INDEX KEY: 0000849145 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-BUSINESS SERVICES, NEC [7389] IRS NUMBER: 592291344 STATE OF INCORPORATION: FL FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 12625 HIGH BLUFF DRIVE STREET 2: SUITE 305 CITY: SAN DIEGO STATE: CA ZIP: 92130 BUSINESS PHONE: 858-847-0655 MAIL ADDRESS: STREET 1: 12625 HIGH BLUFF DRIVE STREET 2: SUITE 305 CITY: SAN DIEGO STATE: CA ZIP: 92130 FORMER COMPANY: FORMER CONFORMED NAME: Counsel RB Capital Inc. DATE OF NAME CHANGE: 20110121 FORMER COMPANY: FORMER CONFORMED NAME: C2 Global Technologies Inc DATE OF NAME CHANGE: 20050812 FORMER COMPANY: FORMER CONFORMED NAME: ACCERIS COMMUNICATIONS INC DATE OF NAME CHANGE: 20040220 CORRESP 1 filename1.htm CORRESP

 

Heritage Global Inc.

12625 High Bluff Drive, Suite 305

San Diego, CA 92130

September 21, 2023

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance
100 F Street, NE

Washington, D.C. 20549
Attention: Rucha Pandit

Re: Heritage Global Inc.

Registration Statement on Form S-3

File No. 333-274514

Acceleration Request

Requested Date: September 25, 2023

Requested Time: 4:00 p.m. Eastern Time

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), Heritage Global Inc. (the “Company”) hereby requests that the above-referenced Registration Statement on Form S-3 (File No. 333-274514) (the “Registration Statement”) be declared effective at the “Requested Date” and “Requested Time” set forth above or at such later time as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission. In making this acceleration request, the Company acknowledges that it is aware of its responsibilities under the Act.

Once the Registration Statement is effective, please orally confirm the event with our counsel, Jon Stanley, of Bass, Berry & Sims PLC by telephone at (615) 742-6257. We also respectfully request that a copy of the written order from the Securities and Exchange Commission verifying the effective date and time of the Registration Statement be sent to our counsel, Jon Stanley, of Bass, Berry & Sims PLC by e-mail at jstanley@bassberry.com.

If you have any questions, please feel free to contact Jon Stanley, of Bass, Berry & Sims PLC at (615) 742-6257. Thank you for your cooperation and prompt attention to this matter.

Sincerely,

Heritage Global Inc.

By: /s/ Brian J. Cobb

Name: Brian J. Cobb

Title: Chief Financial Officer