2004-03-15
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The SEC staff declines to concur with The New Ireland Fund, Inc.'s request to omit a shareholder proposal and its supporting statement in their entirety from the fund's 2004 proxy materials. The staff determines that the proponent, Opportunity Partners, L.P., may cure potential violations of Rule 14a-9 by amending the supporting statement to clarify the reference date for a $12.43 share price, specify the conditions under which shareholders would have received $15.28 per share, identify a referenced Dow Jones news article, and clarify the meaning of getting out at a profit. Unless the proponent provides a revised supporting statement within seven calendar days of receiving this letter, the staff will not recommend enforcement action if the fund omits only the uncorrected portions of the statement.
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March 15, 2004
Paul J. McElroy, Esquire Sullivan & Cromwell LLP 1701 Pennsylvania Avenue Washington, DC 20006-5805
Re: The New Ireland Fund, Inc. - Omission of Shareholder Proposal Pursuant to Rule 14a-8
Dear Mr. McElroy:
In a letter dated February 3, 2004, you notified the staff of the Securities and Exchange Commission of the intent of The New Ireland Fund, Inc. to omit from its proxy materials for its 2004 annual meeting the shareholder proposal and supporting statement submitted by Opportunity Partners, L.P. (the "Proponent"). 1 The Proposal states:
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