SEC Comment Letter 0000000000-24-002961 to Viking Holdings Ltd (VIK) (CIK 0001745201) (VIK)
Viking Holdings Ltd (VIK) (CIK 0001745201)
Date: March 19, 2024 · CIK: 0001745201 · Accession: 0000000000-24-002961
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo March 19, 2024 Torstein Hagen Chief Executive Officer and Chairman of the Board Viking Holdings Ltd 94 Pitts Bay Road Pembroke, Bermuda HM 08 Re:Viking Holdings Ltd Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted March 8, 2024 CIK No. 0001745201 Dear Torstein Hagen: We have reviewed your amended draft registration statement and have the following comment. Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to this letter and your amended draft registration statement or filed registration statement, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our February 21, 2024 letter. Amendment No. 2 to Draft Registration Statement on Form F-1 Market and Industry Data, page 6 1.We note your response to prior comment 1 and reissue it. Please file consents for all commissioned third party reports referenced and summarized in the registration statement pursuant to Rule 436, including the studies by Alter Agents. For reference, see Question 233.02 of Securities Act Rules Compliance and Disclosure Interpretations.
Please contact Jenifer Gallagher at 202-551-3706 or Karl Hiller at 202-551-3686 if you have questions regarding comments on the financial statements and related matters. Please
FirstName LastNameTorstein Hagen Comapany NameViking Holdings Ltd March 19, 2024 Page 2 FirstName LastName Torstein Hagen Viking Holdings Ltd March 19, 2024 Page 2 contact Timothy S. Levenberg at 202-551-3707 or Karina Dorin at 202-551-3763 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Gregg A. Noel, Esq., of Skadden, Arps, Slate, Meagher & Flom LLP
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United States securities and exchange commission logo
March 19, 2024
Torstein Hagen
Chief Executive Officer and Chairman of the Board
Viking Holdings Ltd
94 Pitts Bay Road
Pembroke, Bermuda HM 08
Re:Viking Holdings Ltd
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted March 8, 2024
CIK No. 0001745201
Dear Torstein Hagen:
We have reviewed your amended draft registration statement and have the following
comment.
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
February 21, 2024 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1
Market and Industry Data, page 6
1.We note your response to prior comment 1 and reissue it. Please file consents for all
commissioned third party reports referenced and summarized in the registration
statement pursuant to Rule 436, including the studies by Alter Agents. For reference,
see Question 233.02 of Securities Act Rules Compliance and Disclosure Interpretations.
Please contact Jenifer Gallagher at 202-551-3706 or Karl Hiller at 202-551-3686 if you
have questions regarding comments on the financial statements and related matters. Please
FirstName LastNameTorstein Hagen
Comapany NameViking Holdings Ltd
March 19, 2024 Page 2
FirstName LastName
Torstein Hagen
Viking Holdings Ltd
March 19, 2024
Page 2
contact Timothy S. Levenberg at 202-551-3707 or Karina Dorin at 202-551-3763 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: Gregg A. Noel, Esq., of Skadden, Arps, Slate, Meagher & Flom LLP