-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, WTj5ZfzmoBWcdNmC8RIRrF3Q1kK5aHk0hCY1Umeb7PK1q2orEPJ3COZiAQyLtRMG OhONJ8djqUqQKG5ypCFIsw== 0000000000-05-032771.txt : 20070921 0000000000-05-032771.hdr.sgml : 20070921 20050627154430 ACCESSION NUMBER: 0000000000-05-032771 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050627 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: SPARTAN STORES INC CENTRAL INDEX KEY: 0000877422 STANDARD INDUSTRIAL CLASSIFICATION: WHOLESALE-GROCERIES & GENERAL LINE [5141] IRS NUMBER: 380593940 STATE OF INCORPORATION: MI FISCAL YEAR END: 0329 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 850 76TH ST SW STREET 2: P O BOX 8700 CITY: GRAND RAPIDS STATE: MI ZIP: 49518 BUSINESS PHONE: 6168782000 MAIL ADDRESS: STREET 1: 850 76TH ST SW STREET 2: PO BOX 8700 CITY: GRAND RAPIDS STATE: MI ZIP: 49518 PUBLIC REFERENCE ACCESSION NUMBER: 0000921530-05-000321 LETTER 1 filename1.txt May 23, 2005 By Facsimile (212) 574-2054 and U.S. Mail Thomas L. Kempner President and Chief Executive Officer 61 Broadway New York, New York 10006 Re: Spartan Stores, Inc. Revised Preliminary Schedule 14A filed on May 16, 2005 by Loeb Partners Corporation File No. 000-31127 Dear Mr. Kempner: We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why one or more of our comments are inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments. Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone number listed at the end of this letter. Preliminary Proxy Statement General 1. We note your disclosure in footnote 1 that you may modify your materials if matters other than the election of directors will be considered at Spartan`s annual meeting. Please revise to disclose, if true, that your statement applies to matters set forth on the company`s proxy card and that your representatives will use their discretion on matters that are not included on Spartans` proxy card. Also, supplementally clarify how you plan to "modify" your materials and address any potential need to recirculate a new proxy statement and form of proxy to address additional matters. For example, explain whether you may add additional matters from Spartans` proxy card to your proxy card rather than abstaining from the vote? Voting Procedures, page 5 How will my shares be voted?, page 6 2. You disclose that submitting the proxy card will entitle your representatives to vote in accordance with their discretion on matters not described in "this proxy statement that may arise at the 2005 Annual Meeting." Please revise to clarify, if true, that your representatives will only vote in accordance with their discretion on matters not described in Spartans` 2005 proxy statement. Closing As appropriate, please amend your revised preliminary Schedule 14A in response to these comments. You may wish to provide us with marked copies of the amendment, if required, to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please file your cover letter on EDGAR. Please understand that we may have additional comments after reviewing your amendment and responses to our comments. Please direct any questions to me at (202) 551-3456. You may also contact me via facsimile at (202) 772-9203. Please send all correspondence to us at the following ZIP code: 20549-0303. Very truly yours, Jeffrey B. Werbitt Attorney-Advisor Office of Mergers and Acquisitions -----END PRIVACY-ENHANCED MESSAGE-----