0001564590-21-050021.txt : 20211104 0001564590-21-050021.hdr.sgml : 20211104 20211004160525 ACCESSION NUMBER: 0001564590-21-050021 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20211004 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 hgbl-corresp.htm

Heritage Global Inc.

12625 High Bluff Drive, Suite 305

San Diego, CA 92130

 

October 4, 2021

 

VIA EDGAR

 

United States Securities and Exchange Commission

Division of Corporation Finance
100 F Street, NE

Washington, D.C. 20549
Attention: Jennifer Lopez

 

Re:

Heritage Global Inc.

 

Registration Statement on Form S-3

 

File No. 333-259795

 

 

 

Acceleration Request

 

 

Requested Date: October 6, 2021

Requested Time:4:01 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. 333-259795) (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 D. 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 D. Stanley, of Bass, Berry & Sims PLC by e-mail at jstanley@bassberry.com.

 

If you have any questions, please feel free to contact Jon D. 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/ James Sklar

 

Name:

James Sklar

 

Title:

Executive Vice President, General Counsel and Secretary