2004-03-15

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SEC Division of Investment Management staff letter: The New Ireland Fund, Inc.

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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Securities Exchange Act of 19341934Investment Company Act of 19401940SEC Division of InvestmentManagement staff letter: The …2004-03-15 · this document
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