SEC Comment Letter 0000000000-23-009898 to SUIC Worldwide Holdings Ltd. (SUIC) (CIK 0001394108) (SUIC)
SUIC Worldwide Holdings Ltd. (SUIC) (CIK 0001394108)
Date: Sept. 7, 2023 · CIK: 0001394108 · Accession: 0000000000-23-009898
AI Filing Summary & Sentiment
File numbers found in text: 000-53737
Letter
United States securities and exchange commission logo September 7, 2023 Yanru Zhou Chief Financial Officer SUIC Worldwide Holdings Ltd. 136-20 38th Ave. Unit 3G Flushing , NY 11354 Re:SUIC Worldwide Holdings Ltd. Form 10-K for the Fiscal Year Ended December 31, 2022 Filed June 30, 2023 Form 10-Q for the Quarterly Period Ended March 31, 2023 Filed July 3, 2023 File No. 000-53737 Dear Yanru Zhou: We have reviewed your August 29, 2023 response to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 14, 2023 letter. Amendment No. 1 to Form 10-K for the Fiscal Year Ended December 31, 2022 Report of Independent Registered Public Accounting Firm, page F-1 1.Please refer to our prior comment 2. We see that your auditor changed the date of their report to August 23, 2023. Please tell us if your auditor updated their audit procedures through August 23, 2023. We do not see any changes to the Subsequent Events footnote. Financial Statements Note 1 - Organization and Basis of Presentation , page F-6 2.We re-issue our prior comment 4. Please tell us how you accounted for the acquisition of
FirstName LastNameYanru Zhou Comapany NameSUIC Worldwide Holdings Ltd. September 7, 2023 Page 2 FirstName LastName Yanru Zhou SUIC Worldwide Holdings Ltd. September 7, 2023 Page 2 Midas Touch Technology Co., including the purchase price. Please also tell us when you wrote the investment down to $0. We see from your disclosure in Note 7 that Midas Touch Technology Co. Ltd., is a significant investment of the company, please explain its significance. You may contact Julie Sherman at(202) 551-3640 or Brian Cascio, Accounting Branch Chief, at (202) 551-3676 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
September 7, 2023
Yanru Zhou
Chief Financial Officer
SUIC Worldwide Holdings Ltd.
136-20 38th Ave. Unit 3G
Flushing , NY 11354
Re:SUIC Worldwide Holdings Ltd.
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed June 30, 2023
Form 10-Q for the Quarterly Period Ended March 31, 2023
Filed July 3, 2023
File No. 000-53737
Dear Yanru Zhou:
We have reviewed your August 29, 2023 response to our comment letter and have the
following comments. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
August 14, 2023 letter.
Amendment No. 1 to Form 10-K for the Fiscal Year Ended December 31, 2022
Report of Independent Registered Public Accounting Firm, page F-1
1.Please refer to our prior comment 2. We see that your auditor changed the date of their
report to August 23, 2023. Please tell us if your auditor updated their audit procedures
through August 23, 2023. We do not see any changes to the Subsequent Events footnote.
Financial Statements
Note 1 - Organization and Basis of Presentation , page F-6
2.We re-issue our prior comment 4. Please tell us how you accounted for the acquisition of
FirstName LastNameYanru Zhou
Comapany NameSUIC Worldwide Holdings Ltd.
September 7, 2023 Page 2
FirstName LastName
Yanru Zhou
SUIC Worldwide Holdings Ltd.
September 7, 2023
Page 2
Midas Touch Technology Co., including the purchase price. Please also tell us when you
wrote the investment down to $0. We see from your disclosure in Note 7 that Midas
Touch Technology Co. Ltd., is a significant investment of the company, please explain its
significance.
You may contact Julie Sherman at(202) 551-3640 or Brian Cascio, Accounting Branch
Chief, at (202) 551-3676 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services