SEC Comment Letter 0000000000-23-013276 to Perfect Moment Ltd. (PMNT)
Perfect Moment Ltd.
Date: Dec. 6, 2023 · CIK: 0001849221 · Accession: 0000000000-23-013276
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-274913
Letter
United States securities and exchange commission logo December 6, 2023 Mark Buckley Chief Executive Officer Perfect Moment Ltd. 307 Canalot Studios 222 Kensal Road London W10 5BN United Kingdom Re:Perfect Moment Ltd. Amendment No. 2 to Registration Statement on Form S-1 Filed December 1, 2023 File No. 333-274913 Dear Mark Buckley: 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 a 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 letter, we may have additional comments. Amendment No. 2 to Form S-1 Key Financial Measures, page 45 1.We note your discussions on page 46 of how EBITDA, Adjusted EBITDA and Adjusted operating expenses are calculated. Please expand your disclosure to explain how management uses these measures and why you believe they provide useful information to investors regarding your performance pursuant to Item 10(e)(1)(i)(C) and (D) of Regulation S-K.
FirstName LastNameMark Buckley Comapany NamePerfect Moment Ltd. December 6, 2023 Page 2 FirstName LastName Mark Buckley Perfect Moment Ltd. December 6, 2023 Page 2 Please contact Heather Clark at 202-551-3624 or Kevin Stertzel at 202-551-3723 if you have questions regarding comments on the financial statements and related matters. Please contact Jennifer Angelini at 202-551-3047 or Jay Ingram at 202-551-3397 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Blake Baron
Show Raw Text
United States securities and exchange commission logo
December 6, 2023
Mark Buckley
Chief Executive Officer
Perfect Moment Ltd.
307 Canalot Studios
222 Kensal Road
London W10 5BN United Kingdom
Re:Perfect Moment Ltd.
Amendment No. 2 to Registration Statement on Form S-1
Filed December 1, 2023
File No. 333-274913
Dear Mark Buckley:
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 a 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 letter, we may have additional comments.
Amendment No. 2 to Form S-1
Key Financial Measures, page 45
1.We note your discussions on page 46 of how EBITDA, Adjusted EBITDA and Adjusted
operating expenses are calculated. Please expand your disclosure to explain
how management uses these measures and why you believe they
provide useful information to investors regarding your performance pursuant to Item
10(e)(1)(i)(C) and (D) of Regulation S-K.
FirstName LastNameMark Buckley
Comapany NamePerfect Moment Ltd.
December 6, 2023 Page 2
FirstName LastName
Mark Buckley
Perfect Moment Ltd.
December 6, 2023
Page 2
Please contact Heather Clark at 202-551-3624 or Kevin Stertzel at 202-551-3723 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jennifer Angelini at 202-551-3047 or Jay Ingram at 202-551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Blake Baron