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VIA EDGAR
November 5, 2019
U.S. Securities & Exchange Commission
Division of Corporation Finance
Office of Energy & Transportation
100 F Street, NE
Washington, D.C. 20549
Attn: Mr. Kevin Dougherty
| Re: | Twelve Seas Investment Co |
Preliminary Proxy Statement on Schedule 14A
Filed September 27, 2019
File No. 001-38540
Dear Mr. Dougherty:
On behalf of Twelve Seas Investment Company (the “Company”), we hereby transmit the Company’s response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), on October 24, 2019, regarding the Preliminary Proxy Statement on Schedule 14A submitted to the Commission on September 27, 2019 (the “Proxy Statement”).
For the Staff’s convenience, we have repeated below the Staff’s comments in bold, and have followed each comment with the Company’s response. Disclosure changes made in response to the Staff’s comments will be made in the Amendment No. 1 to the Proxy Statement, to be filed contemporaneously with the submission of this letter.
Proxy Statement on Schedule 14A filed on September 27, 2019
General
| 1. | We refer you to the comments issued separately to Brooge Holdings Limited today relating to the Form F-4 it filed on 9/27/2019. As applicable, please make corresponding revisions to your proxy statement. |
The Staff’s comments relating to the Form F-4 filed on September 27, 2019 are duly noted and all edits and changes made in response to the Staff’s comments to the Form F-4 have also been made in Amendment No. 1 to the Proxy Statement.
Mr. Kevin Dougherty
November 5, 2019
Page 2 of 2
We thank the Staff in advance for its review and consideration of the Proxy Statement. If you have further comments or questions regarding the foregoing, please contact the undersigned at breichel@egsllp.com or by telephone at (212) 370-1300.
| Sincerely, | |
| /s/ Benjamin S. Reichel |
cc: Neil Richardson