SEC Comment Letter for X3 Holdings Co., Ltd. (XTKG) (CIK 0001754323) (XTKGF) — Feb 13, 2019
X3 Holdings Co., Ltd. (XTKG) (CIK 0001754323)
Date: Feb. 13, 2019 · CIK: 0001754323 · Accession: 0000000000-19-002260
AI Filing Summary & Sentiment
File numbers found in text: 333-229128
Letter
February 6, 2019 Ban Lor Chief Executive Officer Powerbridge Technologies Co., Ltd. 1st Floor, Building D2, Southern Software Park Tangjia Bay, Zhuhai, Guangdong 519080, China Re:Powerbridge Technologies Co., Ltd. Registration Statement on Form F-1 Filed January 4, 2019 File No. 333-229128 Dear Mr. Lor: 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. Registration Statement on Form F-1 Executive Compensation Summary Compensation Table, page 99 1.Please revise the table to include information for the last full fiscal year, i.e. December 31, 2018. Refer to Item 6.B of Form 20-F. Consolidated Financial Statements, page F-1 2.Prior to requesting acceleration of effectiveness, please revise to include updated audited financial statements. Refer to Item 8.A.4 of Form 20-F.
FirstName LastNameBan Lor Comapany NamePowerbridge Technologies Co., Ltd. February 6, 2019 Page 2 FirstName LastName Ban Lor Powerbridge Technologies Co., Ltd. February 6, 2019 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 Diane Fritz, Staff Accountant, at 202-551-3331 or Melissa Walsh, Staff Accountant, at 202-551-3224 if you have questions regarding comments on the financial statements and related matters. Please contact Donald Field, Attorney-Advisor, at 202-551-3680 or Dietrich King, Attorney-Advisor, at 202-551-8071 with any other questions. Sincerely, Division of Corporation Finance Office of Information Technologies and Services
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February 6, 2019
Ban Lor
Chief Executive Officer
Powerbridge Technologies Co., Ltd.
1st Floor, Building D2, Southern Software Park
Tangjia Bay, Zhuhai, Guangdong 519080, China
Re:Powerbridge Technologies Co., Ltd.
Registration Statement on Form F-1
Filed January 4, 2019
File No. 333-229128
Dear Mr. Lor:
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.
Registration Statement on Form F-1
Executive Compensation
Summary Compensation Table, page 99
1.Please revise the table to include information for the last full fiscal year, i.e. December 31,
2018. Refer to Item 6.B of Form 20-F.
Consolidated Financial Statements, page F-1
2.Prior to requesting acceleration of effectiveness, please revise to include updated audited
financial statements. Refer to Item 8.A.4 of Form 20-F.
FirstName LastNameBan Lor
Comapany NamePowerbridge Technologies Co., Ltd.
February 6, 2019 Page 2
FirstName LastName
Ban Lor
Powerbridge Technologies Co., Ltd.
February 6, 2019
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 Diane Fritz, Staff Accountant, at 202-551-3331 or Melissa Walsh, Staff
Accountant, at 202-551-3224 if you have questions regarding comments on the financial
statements and related matters. Please contact Donald Field, Attorney-Advisor, at 202-551-3680
or Dietrich King, Attorney-Advisor, at 202-551-8071 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Information Technologies
and Services