With a view towards disclosure by submitting a Schedule 14A that has been annotated with support for each of the assertion made. Support for opinions or beliefs should be self-evident, disclosed in the proxy statement or provided to the staff on a supplemental basis, Please characterize consistently each statement orĪssertion of opinion or belief as such, and ensure that a reasonable basis for each opinion or belief exists. Soliciting Material pursuant to Rule 14a-12 filed April 4, 2006 For reference purposes, the text of comment 7 has been reproduced below and the Issuers response follows it. Set forth below is the Issuers additional response to comment 7 from the Comment Letter. Based on conversations I had with you last week, this letter further supplements and responds to comment 7 of theĬomment Letter regarding Arbinets support that the Board of Directors of Arbinet (the Board) believes that stockholders interests are best served by the election of the Boards director nominees because of, interĪlia, the dissidents past record at Arbinet. In particular, this letter provides additional supplemental support regarding Robert A. Reflected responses to the Staffs comments as well as a separate letter that responded to the comments in the Comment Letter. On April 20, 2006, Arbinet filed via EDGAR its revised Preliminary Proxy Statement on Schedule 14A, which included changes that principally
On April 4, 2006, and the joint Form 8-K Soliciting Material pursuant to Rule 14a-12, which was filed with the Commission on April 4, 2006 (the Rule 14a-12 Filing). Set forth in your comment letter to the Issuer dated April 13, 2006 (the Comment Letter), with respect to the Issuers Preliminary Proxy Statement on Schedule 14A, File Number 0-51063, which was filed with the Commission Company or Arbinet) in response to the comments of the staff (the Staff) of the Division of Corporation Finance of the Securities and Exchange Commission (the Commission) as This letter is submitted on behalf of Arbinet-thexchange, Inc. Special Counsel, Office of Mergers and Acquisitions
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