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SEC Company Response from ASIA PACIFIC WIRE & CABLE CORP LTD (APWC) (CIK 0001026980) (APWC) — Jul 23, 2009

ASIA PACIFIC WIRE & CABLE CORP LTD (APWC) (CIK 0001026980)
Date: July 23, 2009 · CIK: 0001026980 · Accession: 0000950123-09-024638

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SEC Posture
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Summary

Reasoning

File numbers found in text: 333-153796

Referenced dates: May 27, 2009, May 27, 2009

Date
May 28, 2009
Author
Legal Branch Chief
Form
CORRESP
Company
ASIA PACIFIC WIRE & CABLE CORP LTD (APWC) (CIK 0001026980)

Letter

United States Securities and Exchange Commission Post Effective Amendment No. 2 to Registration Statement on Form F-1 Filed on May 13, 2009 File No. 333-153796

Dear Mr. Ingram:

Thank you for your letter dated May 27, 2009. We note your comment regarding the currency of the audited financial statements of the company included in its Registration Statement on Form F-1 and the company is diligently addressing that point and we will provide a definitive response in the near future.

To the best of my knowledge, there have been no offers or sales pursuant to the prospectus since the effective date of the company’s Registration Statement on Form F-1 by the two holders of common shares covered by the prospectus. I am seeking to confirm that point and will provide a definitive response as soon as possible.

Please feel free to contact me if you wish to discuss any of the foregoing.

Very truly yours,

Michael J. Hagan

cc:

Mr. Yuan Chun Tang

Jessica Kane, Esq.

1290 AVENUE OF THE AMERICAS

NEW YORK, NY 10104-0050

TELEPHONE: 212.468.8000

FACSIMILE: 212.468.7900

WWW.MOFO.COM

morrison & foerster llp

new york, san francisco,

los angeles, palo alto,

san diego, washington, d.c.

northern virginia, denver,

sacramento, walnut creek

tokyo, london, beijing,

shanghai, hong kong,

singapore, brussels

July 7, 2009

Writer’s Direct Contact

212.468.8025

mhagan@mofo.com

By Telefacsimile and Mail

Jay Ingram, Esq.

Legal Branch Chief

United States Securities and Exchange Commission

100 F Street, N.E., Mail Stop 7010

Washington, D.C. 20549

Re:

Asia Pacific Wire & Cable Corporation Limited (the “Company”)

Post Effective Amendment No. 2 to

Registration Statement on Form F-1

Filed on May 13, 2009

File No. 333-153796

Dear Mr. Ingram:

As a follow-up to my letter to you dated May 28, 2009, in response to your letter dated May 27, 2009, I wish to inform you that the Company filed today with the Securities and Exchange Commission (the “Commission”) Post-Effective Amendment No. 3 to the Company’s Registration Statement on Form F-1 (the “Registration Statement”), which incorporates by reference the audited financial statements included in the Company’s Form 20-F/A for the fiscal year ended December 31, 2008 filed with the Commission on July 6, 2009.

Furthermore, I wish to inform the Commission that the holders of securities registered under the Registration Statement have confirmed to me that neither of them has made any offers to sell or solicited any offers to purchase common shares pursuant to, or in reliance on, the prospectus that forms part of the Registration Statement since the effective date of the Registration Statement.

Mr. Jay Ingram

July 7, 2009

Page Two

Please feel free to contact me if you wish to discuss any of the foregoing.

Very truly yours,
Michael J. Hagan

Show Raw Text
CORRESP
1
filename1.htm

CORRESP

    1290 AVENUE OF THE AMERICAS

NEW YORK, NY 10104-0050

TELEPHONE: 212.468.8000

FACSIMILE: 212.468.7900

WWW.MOFO.COM

    morrison & foerster llp

new york, san francisco,

los angeles, palo alto,

san diego, washington, d.c.

northern virginia, denver,

sacramento, walnut creek

tokyo, london, beijing,

shanghai, hong kong,

singapore, brussels

    May 28, 2009

    Writer’s Direct Contact

    212.468.8025

    mhagan@mofo.com

By Telefacsimile and Mail

Jay Ingram, Esq.

Legal Branch Chief

United States Securities and Exchange Commission

Mail Stop 7010

Washington, D.C. 20549-7010

    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. Ingram:

Thank you for your letter dated May 27, 2009. We note your comment regarding the currency of the
audited financial statements of the company included in its Registration Statement on Form F-1 and
the company is diligently addressing that point and we will provide a definitive response in the
near future.

To the best of my knowledge, there have been no offers or sales pursuant to the prospectus since
the effective date of the company’s Registration Statement on Form F-1 by the two holders of common
shares covered by the prospectus. I am seeking to confirm that point and will provide a definitive
response as soon as possible.

Please feel free to contact me if you wish to discuss any of the foregoing.

Very truly yours,

Michael J. Hagan

    cc:

    Mr. Yuan Chun Tang

    Jessica Kane, Esq.

    1290 AVENUE OF THE AMERICAS

NEW YORK, NY 10104-0050

TELEPHONE: 212.468.8000

FACSIMILE: 212.468.7900

WWW.MOFO.COM

    morrison & foerster llp

new york, san francisco,

los angeles, palo alto,

san diego, washington, d.c.

northern virginia, denver,

sacramento, walnut creek

tokyo, london, beijing,

shanghai, hong kong,

singapore, brussels

    July 7, 2009

    Writer’s Direct Contact

    212.468.8025

    mhagan@mofo.com

By Telefacsimile and Mail

Jay Ingram, Esq.

Legal Branch Chief

United States Securities and Exchange Commission

100 F Street, N.E., Mail Stop 7010

Washington, D.C. 20549

    Re:

    Asia Pacific Wire & Cable Corporation Limited (the “Company”)

    Post Effective Amendment No. 2 to

    Registration Statement on Form F-1

    Filed on May 13, 2009

    File No. 333-153796

Dear Mr. Ingram:

As a follow-up to my letter to you dated May 28, 2009, in response to your letter dated May 27,
2009, I wish to inform you that the Company filed today with the Securities and
Exchange Commission (the “Commission”) Post-Effective Amendment No. 3 to the Company’s Registration
Statement on Form F-1 (the “Registration Statement”), which incorporates by reference the audited
financial statements included in the Company’s Form 20-F/A for the fiscal year ended December 31,
2008 filed with the Commission on July 6, 2009.

Furthermore, I wish to inform the Commission that the holders of securities registered under the
Registration Statement have confirmed to me that neither of them has made any offers to sell or
solicited any offers to purchase common shares pursuant to, or in reliance on, the prospectus that
forms part of the Registration Statement since the effective date of the Registration Statement.

Mr. Jay Ingram

July 7, 2009

Page Two

Please feel free to contact me if you wish to discuss any of the foregoing.

Very truly yours,

Michael J. Hagan

    cc:

    Mr. Yuan Chun Tang

    Jessica Kane, Esq.