SEC Comment Letter for ASIA PACIFIC WIRE & CABLE CORP LTD (APWC) (CIK 0001026980) (APWC) — Jun 3, 2009
ASIA PACIFIC WIRE & CABLE CORP LTD (APWC) (CIK 0001026980)
Date: June 3, 2009 · CIK: 0001026980 · Accession: 0000000000-09-029554
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-153796
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE Mail Stop 7010 May 27, 2009 Yuan Chun Tang Chief Executive Officer Asia Pacific Wire & Cable Corporation Limited 7/Fl. B, No. 132, Sec. 3 Min-Sheng East Road Taipei, 105, Taiwan People’s Republic of China Re: Asia Pacific Wire & Cable Corporation Limited Post-Effective Amendment No. 2 to Registration Statement on Form F-1 Filed on May 13, 2009 File No. 333-153796
Dear Mr. Tang: We have reviewed your filing and have the following comments. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
General
1. We note that you have included unaudited financial statements through the six month period ending June 30, 2008. Howe ver, it appears that your financial statements are no longer current. Please amend your filing to include updated audited financial statements. See Item 8A to Form 20-F. 2. Please advise us as to whether any offe rs or sales were made pursuant to the prospectus during the period in which the financial statements were not current.
* * * * You may contact Jessica Kane , Staff Attorney, at (202) 551-3235 or me at (202) 551-3397 with any questions. Sincerely, Jay Ingram Legal Branch Chief
Yuan Chun Tang Asia Pacific Wire & Cable Corporation Limited May 27, 2009 Page 2 cc: Michael J. Hagan, Esq. Morrison & Foerster LLP 1290 Avenue of the Americas New York, NY 10104
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
Mail Stop 7010 May 27, 2009 Yuan Chun Tang Chief Executive Officer Asia Pacific Wire & Cable Corporation Limited 7/Fl. B, No. 132, Sec. 3 Min-Sheng East Road Taipei, 105, Taiwan People’s Republic of China
Re: Asia Pacific Wire & Cable Corporation Limited
Post-Effective Amendment No. 2 to
Registration Statement on Form F-1
Filed on May 13, 2009 File No. 333-153796
Dear Mr. Tang:
We have reviewed your filing and have the following comments. We welcome
any questions you may have about our comments or any other aspect of our review. Feel
free to call us at the telephone numbers listed at the end of this letter.
General
1. We note that you have included unaudited financial statements through the six
month period ending June 30, 2008. Howe ver, it appears that your financial
statements are no longer current. Please amend your filing to include updated
audited financial statements. See Item 8A to Form 20-F.
2. Please advise us as to whether any offe rs or sales were made pursuant to the
prospectus during the period in which the financial statements were not current.
* * * *
You may contact Jessica Kane , Staff Attorney, at (202) 551-3235 or me at (202)
551-3397 with any questions.
Sincerely, Jay Ingram Legal Branch Chief
Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited May 27, 2009 Page 2
cc: Michael J. Hagan, Esq. Morrison & Foerster LLP 1290 Avenue of the Americas New York, NY 10104