Posts in No Action Letters
No-Action Letter for Dorian LPG Ltd. Permitted Exclusion of Duplicative Rights Plan Proposal

In Dorian LPG Ltd., 2017 BL 229502 (June 29, 2017), Dorian LPG Ltd. (“Dorian”) asked the staff of the Securities and Exchange Commission (“SEC”) to permit the omission of a shareholder proposal submitted by SEACOR Holdings Inc. ("Shareholder"), requesting Dorian amend its bylaws to require shareholder approval prior to the adoption of any rights plan and to require the redemption of rights issued under existing rights plan. The SEC issued the requested no action letter allowing the exclusion of the proposal under Rule 14a-8(i)(11).

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No-Action Letter for Wal-Mart Store, Inc. Permitted the Exclusion of Corporate Governance Reform Proposal

In Wal-Mart Stores, Inc., 2017 BL 87193 (March 16, 2017), Wal-Mart Stores, Inc. (“Wal-Mart”) asked the staff of the Securities and Exchange Commission (“SEC”) to permit the omission of a proposal submitted by shareholder Jing Zhao (“Shareholder”) requesting Wal-Mart revise its corporate governance guidelines to allow the board of directors to discontinue and remove disqualified members of the board of directors in accordance with applicable laws. The SEC declined to issue the requested no action letter under Rule 14a-8(i)(10).

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