United States securities and exchange commission logo
March 25, 2024
Dean A. Mason
Chief Legal Officer and Secretary
EchoStar Corporation
100 Inverness Terrace East
Englewood, CO 80112
Re: EchoStar
Corporation
SC TO-I/A filed
March 22, 2024
File No. 005-83490
Dear Dean A. Mason:
We have reviewed your filing and have the following comment. In
our comment, we may
ask you to provide us with information so we may better understand your
disclosure.
Please respond to this comment by providing the requested
information or advise us as
soon as possible when you will respond. If you do not believe our
comment applies to your facts
and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have
additional
comments. Defined terms used herein have the same meaning as in your
filing.
Schedule TO-I/A filed March 22, 2024
Questions and Answers, page 6
1. We note your response
to prior comment 1 and the fact that the first sentence of the
answer to Question 24
has been revised from stating that an Eligible Employee s trading
plan will be
cancelled to may be cancelled if an Eligible Employee elects to
exchange
an Eligible Option
covered by a Rule 10b5-1 trading plan. Please explain to us the reason
for this change, and
please revise your disclosure to address specific uncertainties
concerning whether a
participant s trading plan would be canceled if they elected to
participate in the
Exchange Offer.
We remind you that the filing persons are responsible for the
accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please direct any questions to Brian Soares at 202-551-3690 or
Christina Chalk at 202-
551-3263.
Dean A. Mason
EchoStar Corporation
March 25, 2024
Page 2
FirstName LastNameDean A. Mason Sincerely,
Comapany NameEchoStar Corporation
Division of Corporation Finance
March 25, 2024 Page 2 Office of Mergers & Acquisitions
FirstName LastName