ANS
Investments LLC
▪
50
Battery Place, Suite 7F, New York, NY 10280 ▪
▪
Tel:
(212) 945-2080 ▪ Fax: (508) 629-0074 ▪
▪
Email:
jmeer@verizon.net ▪
September
29, 2008
VIA
EDGAR AS CORRESP
Securities
and Exchange Commission
100
F
Street, NE
Washington,
D.C. 20549-3628
Re:
Rule
14a-12 Solicitation Before the Furnishing of a Proxy Statement
Ladies
and Gentlemen:
Pursuant
to Rule 14a-12 promulgated under the Securities Exchange Act of 1934, as
amended, ANS Investments LLC, a Delaware limited liability company (the
“Stockholder”), is hereby filing with the Securities and Exchange Commission
(the “SEC” or the “Commission”), under cover of Schedule 14A, soliciting
material of the Stockholder to be used prior to the furnishing of a proxy
statement.
The
Stockholder currently intends to conduct a proxy solicitation seeking to elect
one (1) nominee, its founder and Chief Executive Officer, Jonah M. Meer (the
"Nominee"), to the Board of Directors of Magellan Petroleum Corporation, a
Delaware corporation (the “Company”), at the Company’s 2008 Annual Meeting of
Stockholders, or any other meeting of stockholders held in lieu thereof, and
any
adjournments, postponements, reschedulings or continuations thereof (the “2008
Annual Meeting”). In addition, the Stockholder intends to present two
stockholder proposals at the 2008 Annual Meeting. Accordingly, on September
11,
2008, the Stockholder delivered a notice to the Company (the “Notification
Letter”) of its intent to nominate one (1) person for election to the Company’s
Board of Directors and to propose two other matters of business for
consideration by stockholders as more specifically described in the Notification
Letter, at the 2008 Annual Meeting, and of its intention to solicit proxies
from
the Company’s stockholders in connection therewith. A copy of the Notification
Letter was previously filed with the Commission on September 11, 2008 as an
exhibit to the Stockholder’s Schedule 14A filed pursuant to Rule 14a-12 under
the Exchange Act.
Securities
and Exchange Commission
September
29, 2008
Page
2
*
* * * *
*
If
the
Staff of the Commission has any questions or comments regarding the accompanying
Schedule 14A filing pursuant to Rule 14a-12 under the Exchange Act or any
aspects of the proxy solicitation referred to therein, please telephone Keith
E.
Gottfried of Blank Rome LLP, counsel to the Stockholder, at (202) 772-5887.
Facsimile transmissions may be sent to him at (202) 572-1434.
|
Very
truly yours,
|
|
|
|
/s/
Jonah M. Meer
|
|
|
|
Jonah
M. Meer
|
|
Chief
Executive Officer
|
cc:
Mr.
Keith
E. Gottfried, Esq.