Correspondence 0001104659-23-116333 from Intelligent Living Application Group Inc. (ILAG) (CIK 0001814963) (ILAG)
Intelligent Living Application Group Inc. (ILAG) (CIK 0001814963)
Date: Nov. 9, 2023 · CIK: 0001814963 · Accession: 0001104659-23-116333
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File numbers found in text: 333-274495
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CORRESP
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Intelligent
Living Application Group Inc.
November 9, 2023
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Manufacturing
100 F Street, N.E.
Washington, D.C. 20549-0405
Attention:
Eranga Dias
Bradley Ecker
Re:
Intelligent Living Application Group Inc.
Registration Statement on Form F-3
Filed September 13, 2023
File No. 333-274495
Dear Mr. Dias and Mr. Ecker:
Intelligent Living Application Group Inc. (“ILAG”
or the “Company” and sometimes referred to as “we” or “our”) is submitting this letter and the following
information in response to a letter, dated October 6, 2023, from the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) with respect to the Company’s Registration Statement on Form F-3
(the “Registration Statement”) filed with the Commission on September 13, 2023.
The Staff’s comments are repeated below
in bold and are followed by the Company’s responses. Capitalized terms used in this letter but otherwise not defined herein shall
have the meanings ascribed to such terms in the Registration Statement.
Form F-3 filed September 13, 2023 General
1. We
note that your registration statement incorporates by reference the risk factors disclosure from your previously filed 2022 Form 20-F.
A review of your 2022 Form 20-F shows that at the time of its filing, you were not certain as to the applicability of CSRC's Trial Administrative
Measures ("Trial Measures") to your company. Please revise this registration statement to state clearly whether you believe
the CSRC's Trial Measures apply to you. If you do not believe the Trial Measures apply to you, please state clearly the reasons for your
determination.
Response: We have revised our registration
statement to state clearly that we don’t believe the CSRC's Trial Measures apply to us and the reasons for such determination on
the cover page and page 3.
If you have any further comments or require any
further information or if any questions should arise in connection with this submission, please call Mr. Jeffrey Li at (703) 618-2503
at FisherBroyles, LLP.
Very truly yours,
Intelligent Living Application Group Inc.
/s/ Bong Lau
Bong Lau
Chief Executive Officer