Correspondence 0001493152-24-020430 from Indonesia Energy Corp Ltd (INDO) (CIK 0001757840) (INDO)
Indonesia Energy Corp Ltd (INDO) (CIK 0001757840)
Date: May 17, 2024 · CIK: 0001757840 · Accession: 0001493152-24-020430
AI Filing Summary & Sentiment
File numbers found in text: 333-278175
Letter
INDONESIA ENERGY CORPORATION LIMITED
GIESMART PLAZA 7th Floor
Jl. Raya Pasar Minggu No. 17A
Pancoran – Jakarta 12780 Indonesia
VIA EDGAR
May 17, 2024
U.S. Securities & Exchange Commission
Division of Corporation Finance
Office of Energy & Transportation
F Street, NE
Washington, D.C. 20549
Attn: Claudia Rios
Karina Dorin
Re: Indonesia Energy Corporation Limited
Registration Statement on Form F-3
Filed March 22, 2024
File No. 333-278175
Ladies and Gentlemen:
Indonesia Energy Corporation Limited (the “Company,” “we,” “our” or “us”) hereby transmits the Company’s response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), on April 5, 2024, regarding the Company’s Registration Statement on Form F-3 (the “Registration Statement”) filed by the Company with the Commission on March 22, 2024.
For the Staff’s convenience, we have repeated below the Staff’s comments in bold, and have followed each comment with the Company’s response. Concurrently with the submission of this response letter, the Company is filing Amendment No. 1 to the Registration Statement (“Amendment No. 1”) via the EDGAR system, which incorporates changes based on the Staff’s comments and other updates to the disclosure.
Registration Statement on Form F-3
General
1. Please update your financial statements in accordance with Item 8.A of Form 20-F. Refer to Item 5(b) of Form F-3.
In response to the Staff’s comment, we updated the financial statements and related disclosures in Amendment No. 1 by incorporating by reference therein our Form 20-F for the fiscal year ended December 31, 2023, which was filed with the Commission on April 26, 2024 (the “Form 20-F”). Please note that other disclosures in Amendment No. 1 (notably in the Prospectus Summary) have also been updated to reflect the updated disclosures contained in the Form 20-F, where applicable.
2. We note the securities being registered pursuant to the base prospectus include depositary shares. Please revise the fee table filed as Exhibit 107 to the registration statement to include the depositary shares.
In response to the Staff’s comment, we have revised the fee table filed as Exhibit 107 to the Amendment No. 1 to include the depositary shares.
******
We thank the Staff for its review of this response. Should you have any questions or require any additional information, please do not hesitate to contact our legal counsel, Lawrence A. Rosenbloom, Esq. of Ellenoff Grossman & Schole LLP, at lrosenbloom@egsllp.com or by telephone at (212) 370-1300.
Sincerely,
Indonesia
Energy Corporation Limited
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filename1.htm
INDONESIA
ENERGY CORPORATION LIMITED
GIESMART
PLAZA 7th Floor
Jl.
Raya Pasar Minggu No. 17A
Pancoran
– Jakarta 12780 Indonesia
VIA
EDGAR
May
17, 2024
U.S.
Securities & Exchange Commission
Division
of Corporation Finance
Office
of Energy & Transportation
100
F Street, NE
Washington,
D.C. 20549
Attn:
Claudia Rios
Karina
Dorin
Re:
Indonesia Energy Corporation Limited
Registration
Statement on Form F-3
Filed
March 22, 2024
File
No. 333-278175
Ladies
and Gentlemen:
Indonesia
Energy Corporation Limited (the “Company,” “we,” “our” or “us”)
hereby transmits the Company’s response to the comment letter received from the staff (the “Staff”) of the U.S.
Securities and Exchange Commission (the “Commission”), on April 5, 2024, regarding the Company’s Registration
Statement on Form F-3 (the “Registration Statement”) filed by the Company with the Commission on March 22, 2024.
For
the Staff’s convenience, we have repeated below the Staff’s comments in bold, and have followed each comment with the Company’s
response. Concurrently with the submission of this response letter, the Company is filing Amendment No. 1 to the Registration Statement
(“Amendment No. 1”) via the EDGAR system, which incorporates changes based on the Staff’s comments and other
updates to the disclosure.
Registration
Statement on Form F-3
General
1. Please
update your financial statements in accordance with Item 8.A of Form 20-F. Refer to Item
5(b) of Form F-3.
In
response to the Staff’s comment, we updated the financial statements and related disclosures in Amendment No. 1 by incorporating
by reference therein our Form 20-F for the fiscal year ended December 31, 2023, which was filed with the Commission on April 26, 2024
(the “Form 20-F”). Please note that other disclosures in Amendment No. 1 (notably in the Prospectus Summary) have
also been updated to reflect the updated disclosures contained in the Form 20-F, where applicable.
1
2. We
note the securities being registered pursuant to the base prospectus include depositary shares.
Please revise the fee table filed as Exhibit 107 to the registration statement to include
the depositary shares.
In
response to the Staff’s comment, we have revised the fee table filed as Exhibit 107 to the Amendment No. 1 to include the depositary
shares.
******
We
thank the Staff for its review of this response. Should you have any questions or require any additional information, please do not hesitate
to contact our legal counsel, Lawrence A. Rosenbloom, Esq. of Ellenoff Grossman & Schole LLP, at lrosenbloom@egsllp.com or by telephone
at (212) 370-1300.
Sincerely,
Indonesia
Energy Corporation Limited
By:
/s/
Wirawan Jusuf
Wirawan
Jusuf
Chief
Executive Officer
cc:
Lawrence
A. Rosenbloom, Esq.
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