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
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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