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Correspondence 0001104659-24-092259 from Troops, Inc. /Cayman Islands/ (TROO) (CIK 0001412095) (TROO)

Troops, Inc. /Cayman Islands/ (TROO) (CIK 0001412095)
Date: Aug. 23, 2024 · CIK: 0001412095 · Accession: 0001104659-24-092259

AI Filing Summary & Sentiment

File numbers found in text: 001-35016

Referenced dates: August 15, 2024

Date
August 23, 2024
Author
/s/ Lawrence S. Venick
Form
CORRESP
Company
Troops, Inc. /Cayman Islands/ (TROO) (CIK 0001412095)

Letter

Via Edgar Transmission Securities and Exchange Commission Division of Corporation Finance Office of Finance Troops., Inc. (the “Company”) Form 20-F for the Fiscal Year ended December 31, 2023 Filed April 19, 2024 File No. 001-35016

Re:

Dear Ms. Guobadia:

As counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated August 15, 2024 from the Securities and Exchange Commission (the “Commission”) in which the staff of the Commission (the “Staff”) commented on the above-referenced Form 20-F (“Form 20-F”).

For the Staff’s convenience, the Staff’s comment has been stated below in its entirety, with the Company’s response set out immediately underneath such comment.

Form 20-F for the Fiscal Year ended December 31, 2023

Exhibit 13.1, page 1

1. We note that the certifications at Exhibit 13.1 appear to relate to your Form 20-F for the fiscal year ended December 31, 2022, rather than the Form 20-F that you filed on April 29, 2024, covering the fiscal year ended December 31, 2023.

Please file a complete amendment to your annual report to include currently dated certifications that reference and pertain to the more recent annual report.

Response: We respectfully advise the Staff that we have amended our annual report to include the currently dated certificates that reference and pertain to the more recent annual report.

* * *

Please contact the undersigned at (852) 3923-1188 if you have any questions with respect to the responses contained in this letter.

Sincerely,
/s/ Lawrence S. Venick

Show Raw Text
CORRESP
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filename1.htm

August 23, 2024

    Via
    Edgar Transmission

    Ms. Yolanda Guobadia

    Securities and Exchange Commission

    Division of Corporation Finance

    Office of Finance

    Washington, D.C. 20549

    Re:

    Troops., Inc. (the “Company”)

    Form 20-F for the Fiscal Year ended
    December 31, 2023

    Filed April 19, 2024

    File No. 001-35016

Dear Ms. Guobadia:

As counsel for
the Company and on its behalf, this letter is being submitted in response to the letter dated August 15, 2024 from the Securities and
Exchange Commission (the “Commission”) in which the staff of the Commission (the “Staff”) commented
on the above-referenced Form 20-F (“Form 20-F”).

For the Staff’s
convenience, the Staff’s comment has been stated below in its entirety, with the Company’s response set out immediately underneath
such comment.

Form 20-F for the Fiscal Year ended
December 31, 2023

Exhibit 13.1, page 1

1.
We note that the certifications at Exhibit 13.1 appear to relate to your Form 20-F for the fiscal year ended December 31, 2022, rather than the Form 20-F that you filed on April 29, 2024, covering the fiscal year ended December 31, 2023.

Please file a complete amendment to your annual report to include currently dated certifications that reference and pertain to the more recent annual report.

Response:  We respectfully advise the Staff that we have amended our annual report to include the currently dated certificates
that reference and pertain to the more recent annual report.

* * *

Please contact
the undersigned at (852) 3923-1188 if you have any questions with respect to the responses contained in this letter.

Sincerely,

    /s/ Lawrence S. Venick

    Lawrence S. Venick

    Direct Dial: +852.3923.1188

    Email: lvenick@loeb.com