The Lone Star Value Group notes that the referenced statement addresses the qualifications and value that its Nominees would bring to the Board if elected.  The statement does not explicitly or implicitly refer to the current directors.  Notwithstanding the above, the Lone Star Value Group, believes that if such statement were interpreted as an implicit belief and opinion that the current directors lack “appropriate and relevant skill sets and a shared objective of enhancing value for the benefit of all Hudson stockholders,” then such a belief would be well-substantiated and the statement in full compliance with Note b to Rule 14a-9.  As detailed by the Lone Star Value Group in the Reasons for the Solicitation section of the Proxy Statement, HSON has deeply underperformed, both operationally and in the market, for an extended period of time including for the duration of the tenure of the two contested directors.  In that context it is reasonable to conclude, that the incumbents either lack the “appropriate and relevant skill sets” to turnaround the business or lack the “shared objective of enhancing value for the benefit of all Hudson stockholders.”

The Lone Star Value Group acknowledges the Staff’s comment and provides the following supplemental response.  As stated in the Proxy Statement, Lone Star Value Investors has purchased the Shares reported owned by it in the Proxy Statement with the working capital of the fund, and Mr. Radoff purchased the Shares he owns with personal funds.  Lone Star Value Investors is a limited partnership investment vehicle and its investment manager has full discretion and investment control over the acquisition, disposition and voting of the Shares reported owned by it.   The limited partners of Lone Star Value Investors do not have investment discretion over the Shares held by Lone Star Value Investors. Mr. Radoff has full discretion and investment control over the acquisition, disposition and voting of the Shares he owns.

As such, The Lone Star Value Group believes that the Shares reported owned by Lone Star Value Investors and Mr. Radoff, respectively, are in each case appropriately deemed directly beneficially owned by Lone Star Value Investors and Mr. Radoff.  As a result any director candidate of the Lone Star Value Group if elected to the Board should appropriately be deemed a direct shareholder representative on the Board.

The Lone Star Value Group acknowledges the Staff’s comment and has revised the disclosure accordingly. See page 5 of the Proxy Statement.

The Lone Star Value Group acknowledges the Staff’s comment and has revised the Proxy Statement to provide clarification as to the actions that the Nominees believe may be necessary to enhance stockholder value and to expressly state that the Lone Star Value believes that one of the Nominees should chair the Compensation Committee of the Board. See page 9 of the Proxy Statement.

The Lone Star Value Group acknowledges the Staff’s comment and has revised the Proxy Statement to remove the implication that membership in a group under Rule 13d-5 alone, without more, results in shared beneficial ownership among group members. (SEC Q & A, Question No. 105.06 (January 3, 2014): “The formation of a group under Rule 13d-5(b), without more, does not result in the attribution of beneficial ownership to each group member of the securities beneficially owned by other members.”).  See pages 12 and 18 of the Proxy Statement.

The Lone Star Value Group acknowledges the Staff’s comment and has revised its disclosure in the Proxy Statement accordingly. The Lone Star Value Group agrees that, in a contested election, a broker does not have discretionary authority to vote on any proposals to be voted on at the meeting, whether routine or not. See page 16 of the Proxy Statement.

The Lone Star Value Group acknowledges the Staff’s comment regarding the use of Rule 14a-5(c) and confirms its intent to rely on Rule 14a-5(c).  It is the Lone Star Value Group’s understanding that to the extent the Proxy Statement refers to information contained in the Company’s proxy statement, the Lone Star Value Group can mail its proxy statement no earlier than the filing of the Company’s definitive proxy statement with the SEC.  However, the Lone Star Value Group intends to mail its proxy statement to shareholders no earlier than the filing of the Company’s definitive proxy statement with the SEC.

The Lone Star Value Group acknowledges the Staff’s comment and confirms its understanding that all written soliciting materials, including any scripts to be used in soliciting proxies must be filed under the cover of Schedule 14A on the date of first use and the Lone Star Group further confirms its intention to do so.

The Lone Star Value Group acknowledges the Staff’s comment and has revised the Proxy Statement accordingly. The Lone Star Value Group confirms that it will clearly specify on the form of proxy in bold-face type how it intends to vote on Proposal 2 prior to filing a definitive proxy statement with the Commission. Please see the Form of Proxy Card and pages 1 and 14 of the Proxy Statement.

In connection with responding to the Staff’s comments, a certificate signed by each of the participants containing the three acknowledgments requested by the Staff is attached hereto.

The Staff is invited to contact the undersigned with any comments or questions it may have. We would appreciate your prompt advice as to whether the Staff has any further comments.

Aneliya S. Crawford, Esq., Olshan Frome Wolosky LLP

In connection with responding to the comments of the Staff of the Securities and Exchange Commission (“SEC”) relating to the revised preliminary proxy statement on Schedule 14A (the “Proxy Statement”) filed by the undersigned on March 19, 2014, each of the undersigned acknowledges the following: