SEC Comment Letter for Cenntro Inc. (CENN) (CIK 0001707919) (CENN) — Apr 5, 2018
Cenntro Inc. (CENN) (CIK 0001707919)
Date: April 5, 2018 · CIK: 0001707919 · Accession: 0000000000-18-010284
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-223786
Letter
Mail Stop 3561 April 4, 2018 Via E -Mail Justin Davis -Rice Executive Director Bendon Group Holdings Limited c/o Bendon Limited Building 7C, Huntley Street Alexandria NSW 2015, Australia
Re: Bendon Group Holdings Limited Registration Statement on Form F -4 Filed March 20, 2018 File No. 333-223786
Dear Mr. Davis -Rice:
We have reviewed your registration statement 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 this letter by amending your registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments.
Business of Bendon, page 151
1. We note that you are continually exploring the use of new technologies, such as blockchain technology. Please clarify how you intend to use blockchain trading platforms to provide low cost trade finance.
Certain Relationshi ps and Related Person Transactions, page 180
2. Please provide the related party transaction disclosure for the period since the beginning of the company’s preceding three financial years up to the date of the filing. See Item 7.B of Form 20 -F and Instructi on to Item 404 of Regulation S -K.
Justin Davis -Rice Bendon Group Holdings Limited April 4, 2018 Page 2
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration . Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.
You may contact Jonathan Burr at (202) 551 -5833 or Brigitte Lippmann at (202) 551- 3713 with any questions.
Sincerely,
/s/ Brigitte Lippmann (for)
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Mail Stop 3561 April 4, 2018 Via E -Mail Justin Davis -Rice Executive Director Bendon Group Holdings Limited c/o Bendon Limited Building 7C, Huntley Street Alexandria NSW 2015, Australia Re: Bendon Group Holdings Limited Registration Statement on Form F -4 Filed March 20, 2018 File No. 333-223786 Dear Mr. Davis -Rice: We have reviewed your registration statement 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 this letter by amending your registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Business of Bendon, page 151 1. We note that you are continually exploring the use of new technologies, such as blockchain technology. Please clarify how you intend to use blockchain trading platforms to provide low cost trade finance. Certain Relationshi ps and Related Person Transactions, page 180 2. Please provide the related party transaction disclosure for the period since the beginning of the company’s preceding three financial years up to the date of the filing. See Item 7.B of Form 20 -F and Instructi on to Item 404 of Regulation S -K. Justin Davis -Rice Bendon Group Holdings Limited April 4, 2018 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration . Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. You may contact Jonathan Burr at (202) 551 -5833 or Brigitte Lippmann at (202) 551- 3713 with any questions. Sincerely, /s/ Brigitte Lippmann (for) John Reynolds Assistant Director Office of Beverages, Apparel, and Mining cc: Jeffrey M. Gallant, Esq. Graubard Miller