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SEC Comment Letter for E-Home Household Service Holdings Ltd (EJH) (CIK 0001769768) (EJH) — Aug 7, 2019

E-Home Household Service Holdings Ltd (EJH) (CIK 0001769768)
Date: Aug. 7, 2019 · CIK: 0001769768 · Accession: 0000000000-19-012167

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
August 7, 2019
Author
Wenshan Xie
Form
UPLOAD
Company
E-Home Household Service Holdings Ltd (EJH) (CIK 0001769768)

Letter

August 7, 2019 Wenshan Xie Chief Executive Officer E-Home Household Service Holdings Ltd Floor 9, Building 14, HaixiBaiyue Town No. 14 Duyuan Road, Luozhou Town Cangshan District, Fuzhou City 350001 People’s Republic of China Re:E-Home Household Service Holdings Ltd. Amended Draft Registration Statement on Form F-1 Submitted August 1, 2019 CIK No. 0001769768 Dear Mr. Xie: We have reviewed your amended draft 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 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 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 the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. Amended DRS on Form F-1 submitted August 1, 2019 Principal Shareholders, page 74 1.We note footnote (4) to the beneficial ownership table indicating the voting agreement between E-home Group Limited and Lucky Max Global Limited. As a result of this agreement, it appears that Mr. Xie is the beneficial owner of approximately 54% of the company's shares. Please revise the table, the chart depicting your corporate structure on page 49, and include a risk factor highlighting Mr. Xie's controlling interest in the company.

FirstName LastNameWenshan Xie Comapany NameE-Home Household Service Holdings Ltd August 7, 2019 Page 2 FirstName LastName Wenshan Xie E-Home Household Service Holdings Ltd August 7, 2019 Page 2 2.As you have now disclosed the minimum and maximum number of shares to be offered, please complete the table in your next submission. You may contact Charles Eastman, Staff Accountant, at (202) 551-3794 or Robert S. Littlepage, Accountant Branch Chief, at (202) 551-3361 if you have questions regarding the financial statements and related matters. Please contact Gregory Dundas, Attorney-Adviser, at (202) 551-3436 or Larry Spirgel, Assistant Director, at (202) 551-3810 with any other questions. Sincerely, Division of Corporation Finance Office of Telecommunications cc: Kevin Sun, Esq.

Show Raw Text
August 7, 2019
Wenshan Xie
Chief Executive Officer
E-Home Household Service Holdings Ltd
Floor 9, Building 14, HaixiBaiyue Town
No. 14 Duyuan Road, Luozhou Town
Cangshan District, Fuzhou City 350001
People’s Republic of China
Re:E-Home Household Service Holdings Ltd.
Amended Draft Registration Statement on Form F-1
Submitted August 1, 2019
CIK No. 0001769768
Dear Mr. Xie:
            We have reviewed your amended draft 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 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 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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amended DRS on Form F-1 submitted August 1, 2019
Principal Shareholders, page 74
1.We note footnote (4) to the beneficial ownership table indicating the voting agreement
between E-home Group Limited and Lucky Max Global Limited.  As a result of this
agreement, it appears that Mr. Xie is the beneficial owner of approximately 54% of the
company's shares.  Please revise the table, the chart depicting your corporate structure on
page 49, and include a risk factor highlighting Mr. Xie's controlling interest in the
company.

 FirstName LastNameWenshan Xie
 Comapany NameE-Home Household Service Holdings Ltd
 August 7, 2019 Page 2
 FirstName LastName
Wenshan Xie
E-Home Household Service Holdings Ltd
August 7, 2019
Page 2
2.As you have now disclosed the minimum and maximum number of shares to be offered,
please complete the table in your next submission.
            You may contact Charles Eastman, Staff Accountant, at (202) 551-3794 or Robert S.
Littlepage, Accountant Branch Chief, at (202) 551-3361 if you have questions regarding the
financial statements and related matters.  Please contact Gregory Dundas, Attorney-Adviser, at
(202) 551-3436 or Larry Spirgel, Assistant Director, at (202) 551-3810 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Telecommunications
cc:       Kevin Sun, Esq.