Correspondence 0001554795-23-000319 from SUIC Worldwide Holdings Ltd. (SUIC) (CIK 0001394108) (SUIC)
SUIC Worldwide Holdings Ltd. (SUIC) (CIK 0001394108)
Date: Oct. 4, 2023 · CIK: 0001394108 · Accession: 0001554795-23-000319
AI Filing Summary & Sentiment
File numbers found in text: 000-53737
Letter
Via EDGAR Only United States Securities and Exchange Commission Attention: Julie Sherman Division of Corporation Finance Office of Industrial Applications and Service Filed June 30, 2023 Form 10-Q for the Quarterly Period Ended March 31, 2023 Filed July 3, 2023 File No. 000-53737
Re: SUIC Worldwide Holdings Ltd.
Dear Ms. Julie Sherman:
Please be advised that I am the duly authorized CFO of SUIC Worldwide Holdings, Ltd., the above-referenced issuer (the “Company”). This letter is in response to the comments of the Branch Chief of the U.S. Securities and Exchange Commission (the “Commission”), dated September 28, 2023, with respect to the above-referenced filings (the “Comment Letter”), and to illustrate the amendments made to the filings on the Form 10K/A, 10Q/A filed herewith. Our responses follow the text of each comment and are produced consecutively for your convenience and edits are in underline and strikethrough formatting to show changes.
Amendment No. 1 to Form 10-K for the Fiscal Year Ended December 31,
Report of Independent Registered Public Accounting Firm, page F-1
We see from your response to our prior comment 1 that you changed the date of the auditor's report. Please file the report as prepared by your auditor. It is not appropriate for you to revise their report. The date of the report needs to coincide with the work performed by them and should be dated by the auditor. Please discuss with your auditor and file the report issued by them. Please also ask your auditor to tell us if they updated their audit procedures at any point after the date of their report.
Response: After discuss with our auditor, we have filed 10K/A with the date to coincide with the work performed by auditor. Our auditor does not update their audit procedures.
☐ the company is responsible for the adequacy and accuracy of the disclosure in the filing;
☐ staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
☐ the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Should you have any questions or require any further information, please do not hesitate to contact us.
Sincerely,
SUIC Worldwide Holdings Ltd.
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CORRESP 1 filename1.htm SUIC Worldwide Holdings Ltd. Oct 4, 2023 Via EDGAR Only United States Securities and Exchange Commission Washington, D.C. 20549 Attention: Julie Sherman Division of Corporation Finance Office of Industrial Applications and Service 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 Ms. Julie Sherman: Please be advised that I am the duly authorized CFO of SUIC Worldwide Holdings, Ltd., the above-referenced issuer (the “Company”). This letter is in response to the comments of the Branch Chief of the U.S. Securities and Exchange Commission (the “Commission”), dated September 28, 2023, with respect to the above-referenced filings (the “Comment Letter”), and to illustrate the amendments made to the filings on the Form 10K/A, 10Q/A filed herewith. Our responses follow the text of each comment and are produced consecutively for your convenience and edits are in underline and strikethrough formatting to show changes. 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 We see from your response to our prior comment 1 that you changed the date of the auditor's report. Please file the report as prepared by your auditor. It is not appropriate for you to revise their report. The date of the report needs to coincide with the work performed by them and should be dated by the auditor. Please discuss with your auditor and file the report issued by them. Please also ask your auditor to tell us if they updated their audit procedures at any point after the date of their report. Response: After discuss with our auditor, we have filed 10K/A with the date to coincide with the work performed by auditor. Our auditor does not update their audit procedures. ☐ the company is responsible for the adequacy and accuracy of the disclosure in the filing; ☐ staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and ☐ the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Should you have any questions or require any further information, please do not hesitate to contact us. Sincerely, SUIC Worldwide Holdings Ltd. By: /s/ Yanru Zhou ___________________________ Name: Yanru Zhou Title: CFO