Correspondence 0001731122-24-000059 from CDT Environmental Technology Investment Holdings Ltd (CDTG)
CDT Environmental Technology Investment Holdings Ltd
Date: Jan. 11, 2024 · CIK: 0001793895 · Accession: 0001731122-24-000059
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-252127
Letter
January 11, 2024
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C.
Attn: Irene Barberena-Meissner
Laura Nicholson
Yong Kim
Gus Rodriguez
Re: CDT Environmental Technology Investment Holdings Limited
Amendment No. 12 to Registration Statement on Form F-1
Filed December 20, 2023
File No. 333-252127
Ladies and Gentlemen:
CDT Environmental Technology Investment Holdings Limited (the “Company”), hereby provides the following information in response to the comments received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on January 8, 2024 with respect to the above-referenced filing. The Company’s responses below are preceded by a reproduction of the corresponding comments from the Staff in bold.
If the Staff would like hard copies of Amendment No. 13 to the Registration Statement on Form F-1 (the “Registration Statement”) as filed with the Commission on the date hereof, marked against Amendment No. 12 to the Registration Statement on Form F-1 as filed with the Commission on December 20, 2023, please so advise and we would be happy to provide such copies. All page number references contained in the Company’s responses below correspond to the page numbers in the Registration Statement. Any capitalized terms used herein but not defined herein shall have the meanings given to them in the Registration Statement.
Amendment No. 12 to Registration Statement on Form F-1
1. Please provide updated compensation disclosure for the last full financial year. Please also update the Related Party Transactions section that begins on page 87. Refer to Items 6.B and 7.B of Form 20-F.
Company Response: The Company acknowledges the Staff’s comment and has revised the disclosure on pages 86 and 87 of the Registration Statement accordingly. The Company has confirmed that there are no available updates to the Related Party Transactions section as of the date of the Registration Statement.
2. We note your disclosure in your prospectus regarding advice of your PRC legal counsel regarding permissions, consents and approvals, including your disclosure on your prospectus cover page and your disclosure on page 24. Please file such counsel’s consent as an exhibit to the registration statement.
Company Response: The consent of the Company’s PRC legal counsel, Beijing Dacheng Law Offices, LLP (Fuzhou), has been filed as Exhibit 23.4 to the Registration Statement.
***
If you have any questions or comments concerning these responses, please do not hesitate to contact me by telephone at 86-0755-86667996 or by e-mail at liyunwu@cdthb.cn or the Company’s counsel by telephone at 305-539-3306 or by email at clayton.parker@klgates.com.
Sincerely,
/s/ Yunwu Li
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CORRESP
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filename1.htm
January 11, 2024
VIA EDGAR
U.S. Securities
and Exchange Commission
Division of Corporation
Finance
100 F. Street,
N.E.
Washington, D.C.
20549
Attn:
Irene Barberena-Meissner
Laura Nicholson
Yong Kim
Gus Rodriguez
Re:
CDT Environmental Technology Investment Holdings Limited
Amendment No. 12 to Registration Statement on Form F-1
Filed December 20, 2023
File No. 333-252127
Ladies and Gentlemen:
CDT Environmental Technology
Investment Holdings Limited (the “Company”), hereby provides the following information in response to the comments
received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
on January 8, 2024 with respect to the above-referenced filing. The Company’s responses below are preceded by a reproduction
of the corresponding comments from the Staff in bold.
If the Staff would like
hard copies of Amendment No. 13 to the Registration Statement on Form F-1 (the “Registration Statement”) as
filed with the Commission on the date hereof, marked against Amendment No. 12 to the Registration Statement on Form F-1 as filed
with the Commission on December 20, 2023, please so advise and we would be happy to provide such copies. All page number references
contained in the Company’s responses below correspond to the page numbers in the Registration Statement. Any capitalized
terms used herein but not defined herein shall have the meanings given to them in the Registration Statement.
Amendment No. 12 to Registration Statement
on Form F-1
1.
Please provide updated compensation disclosure for the last full financial year. Please also update the Related Party Transactions section that begins on page 87. Refer to Items 6.B and 7.B of Form 20-F.
Company Response: The Company
acknowledges the Staff’s comment and has revised the disclosure on pages 86 and 87 of the Registration Statement accordingly.
The Company has confirmed that there are no available updates to the Related Party Transactions section as of the date of the Registration
Statement.
2.
We note your disclosure in your prospectus regarding advice of your PRC legal counsel regarding permissions, consents and approvals, including your disclosure on your prospectus cover page and your disclosure on page 24. Please file such counsel’s consent as an exhibit to the registration statement.
Company Response: The consent
of the Company’s PRC legal counsel, Beijing Dacheng Law Offices, LLP (Fuzhou), has been filed as Exhibit 23.4 to the Registration
Statement.
***
If you have any questions
or comments concerning these responses, please do not hesitate to contact me by telephone at 86-0755-86667996 or by e-mail at liyunwu@cdthb.cn
or the Company’s counsel by telephone at 305-539-3306 or by email at clayton.parker@klgates.com.
Sincerely,
/s/ Yunwu Li
Yunwu Li, Chief Executive Officer and Chairman of the Board of
Directors
cc:
Clayton E. Parker, K&L Gates LLP