SEC Comment Letter for Industrial Technical Holdings Corp (CIK 0001786989) — Mar 31, 2020
Industrial Technical Holdings Corp (CIK 0001786989)
Date: March 31, 2020 · CIK: 0001786989 · Accession: 0000000000-20-002768
AI Filing Summary & Sentiment
File numbers found in text: 333-233613
Letter
March 31, 2020 Andreas Spiegler Chairman and Chief Executive Officer Industrial Technical Holdings Corporation Huanxiu Street Office, Shuanglong Industrial Park 266201 Jimo Qingdao, China Re:Industrial Technical Holdings Corporation Amendment No. 6 to Registration Statement on Form F-1 Filed March 30, 2020 File No. 333-233613 Dear Mr. Spiegler: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comment applies 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 this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our March 27, 2020 letter. Amendment No. 6 to Registration Statement on Form F-1 filed March 30, 2020 Impact of COVID-19 Outbreak, page 79 1.Please expand your revisions in response to prior comment 2 to clarify why you are engaged in the measures discussed in the last sentence given that your other disclosures in this section indicate that the outbreak did not have a material impact on your results of operations or financial condition. Please also clarify for how long your factory and suppliers were shut down and the related impact on you.
FirstName LastNameAndreas Spiegler Comapany NameIndustrial Technical Holdings Corporation March 31, 2020 Page 2 FirstName LastName Andreas Spiegler Industrial Technical Holdings Corporation March 31, 2020 Page 2 You may contact Michael Fay at (202) 551-3812 or Brian Cascio, Accounting Branch Chief, at (202) 551-3676 if you have questions regarding comments on the financial statements and related matters. Please contact Geoff Kruczek at (202) 551-3641 or Russell Mancuso at (202) 551-3617 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Andrew J. Befumo, Esq.
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March 31, 2020
Andreas Spiegler
Chairman and Chief Executive Officer
Industrial Technical Holdings Corporation
Huanxiu Street Office, Shuanglong Industrial Park
266201 Jimo
Qingdao, China
Re:Industrial Technical Holdings Corporation
Amendment No. 6 to Registration Statement on Form F-1
Filed March 30, 2020
File No. 333-233613
Dear Mr. Spiegler:
We have reviewed your amended registration statement and have the following
comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comment applies 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 this comment, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our March 27, 2020 letter.
Amendment No. 6 to Registration Statement on Form F-1 filed March 30, 2020
Impact of COVID-19 Outbreak, page 79
1.Please expand your revisions in response to prior comment 2 to clarify why you are
engaged in the measures discussed in the last sentence given that your other disclosures in
this section indicate that the outbreak did not have a material impact on your results of
operations or financial condition. Please also clarify for how long your factory and
suppliers were shut down and the related impact on you.
FirstName LastNameAndreas Spiegler
Comapany NameIndustrial Technical Holdings Corporation
March 31, 2020 Page 2
FirstName LastName
Andreas Spiegler
Industrial Technical Holdings Corporation
March 31, 2020
Page 2
You may contact Michael Fay at (202) 551-3812 or Brian Cascio, Accounting Branch
Chief, at (202) 551-3676 if you have questions regarding comments on the financial statements
and related matters. Please contact Geoff Kruczek at (202) 551-3641 or Russell Mancuso at
(202) 551-3617 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Andrew J. Befumo, Esq.