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Correspondence 0001493152-23-006560 from ADDENTAX GROUP CORP. (ATXG) (CIK 0001650101) (ATXG)

ADDENTAX GROUP CORP. (ATXG) (CIK 0001650101)
Date: March 2, 2023 · CIK: 0001650101 · Accession: 0001493152-23-006560

AI Filing Summary & Sentiment

File numbers found in text: 333-269409

Referenced dates: March 1, 2023

Date
February 21, 2023
Author
Lawrence S. Venick
Form
CORRESP
Company
ADDENTAX GROUP CORP. (ATXG) (CIK 0001650101)

Letter

Division of Corporation Finance Office of Trade & Services Securities and Exchange Commission F Street, N.E. Washington, D.C. 20549

Re: Addentax Group Corp.

Dear SEC Officers:

On behalf of Addentax Group Corp. (the “Company”), we have set forth below responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission contained in its letter dated March 1, 2023 with respect to the Registration Statement on Form S-1, No. 333-269409 (“F-1”), submitted on February 21, 2023 by the Company. For your convenience, the text of the Staff’s comments is set forth below in bold, followed in each case by the Company’s responses. Please note that all references to page numbers in the responses are references to the page numbers in revised Form S-1 (the “Revised S-1”), filed concurrently with the submission of this letter in response to the Staff’s comments.

Amendment No. 1 to Registration Statement on Form S-1, filed February 21, 2023

Prospectus Summary, page 1

PRC Limitation on Overseas Listing and Share Issuance, page 5

1. We note your response to comment 4 and reissue in part. Please disclose that you have not relied upon an opinion of counsel with respect to your conclusions that you do not need any additional permissions and approvals to operate your business, and disclose why you reached that decision (i.e., the explanation you provided in your response letter).

Response: In response to the Staff’s comment, the Company has added the relevant disclosure on page 5 of the Revised S-1.

Should you have any questions relating to the foregoing or wish to discuss any aspect of the Company’s filing, please contact me at +852.5600.0188.

Very
truly yours,
/s/
Lawrence S. Venick

Show Raw Text
CORRESP
1
filename1.htm

March
2, 2023

    Re:
    Addentax
    Group Corp.

    Registration
    Statement on Form S-1

    Filed
    February 21, 2023

    No.
    333-269409

Division
of Corporation Finance

Office
of Trade & Services

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Dear
SEC Officers:

On
behalf of Addentax Group Corp. (the “Company”), we have set forth below responses to the comments of the staff (the “Staff”)
of the Securities and Exchange Commission contained in its letter dated March 1, 2023 with respect to the Registration Statement on Form
S-1, No. 333-269409 (“F-1”), submitted on February 21, 2023 by the Company. For your convenience, the text of the Staff’s
comments is set forth below in bold, followed in each case by the Company’s responses. Please note that all references to page
numbers in the responses are references to the page numbers in revised Form S-1 (the “Revised S-1”), filed concurrently with
the submission of this letter in response to the Staff’s comments.

Amendment
No. 1 to Registration Statement on Form S-1, filed February 21, 2023

Prospectus
Summary, page 1

PRC
Limitation on Overseas Listing and Share Issuance, page 5

1.
We note your response to comment 4 and reissue in part. Please disclose that you have not relied upon an opinion of counsel with respect
to your conclusions that you do not need any additional permissions and approvals to operate your business, and disclose why you reached
that decision (i.e., the explanation you provided in your response letter).

Response:
In response to the Staff’s comment, the Company has added the relevant disclosure on page 5 of the Revised S-1.

Should
you have any questions relating to the foregoing or wish to discuss any aspect of the Company’s filing, please contact me at +852.5600.0188.

    Very
    truly yours,

    /s/
    Lawrence S. Venick

    Lawrence
    S. Venick