Firsthand Technology Value Fund, Inc. - Exclusion of Stockholder Proposal Pursuant to Rule 14a-8

PAUL
HASTI NGS
BY HAND DELIVERY
Division of Investment Management
Office of Disclosure and Review
100 F Street, N.E.
Washington, D.C. 20549-8626
Re: Firsthand Technology Value Fund, Inc. - Exclusion of Stockholder Proposal Pursuant to Rule 14a-8 Ladies and Gentlemen:
We submit this letter on behalf of our client, Firsthand Technology Value Fund, Inc. (the "Fund'), a Maryland corporation that has elected treatment as a business development company under the Investment Company Act of 1940, as amended (the "Investment Company Acf'). We are seeking the confirmation of the staff of the Securities and Exchange Commission (the "Commission") that it will not recommend enforcement action to the Commission if, in reliance on Rule 14a-8 under the Securities Exchange Act of 1934, as amended (the "Exchange Acf'), the Fund were to omit the enclosed shareholder proposal (the " Proposaf') and supporting statement (the "Supporting Statement') submitted by Full Value Partners, L.P. (the "Proponent') from the Fund's proxy materials for its next meeting of shareholders to be held on or about May 23, 2014 (the "Proxy Materials" ). In accordance with the requirements of Rule 14a-8U) under the Exchange Act, we have enclosed six copies of this letter and concurrently sent copies of this correspondence to the Proponent. A copy of the Proponent's letter containing the Proposal and the Supporting Statement is attached hereto as Exhibit A. We are submitting this letter to the Commission more than eighty calendar days before the Fund intends to file its definitive Proxy Materials with the Commission. I. SUMMARYOFTHEPROPOSALANDBACKGROUND On April 22, 2013, the Fund received a letter from Phillip Goldstein, a principal of the Proponent's general partner, requesting that the following Proposal be included in the proxy materials for the next meeting of Fund shareholders for which the Proposal is timely submitted:
RESOLVED: The Investment Management Agreement between the Fund and Firsthand Fund Capital Management, Inc., (FCM) shall be terminated as soon as possible. The Proponent was identified in the letter as a member of the Bulldog Investors group (defined below) that filed a Schedule 13D amendment with the Commission on April 15, 2013. Paul Hastings LLP I 87515th Street, N.W. I Washington, DC 20005 t: +1.202.551.1700 I www.paulhastings.com