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
AI Filing Summary & Sentiment
File numbers found in text: 333-153796
Referenced dates: May 27, 2009, May 27, 2009
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CORRESP
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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.