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SEC Comment Letter 0000000000-24-009308 to J-Star Holding Co., Ltd. (YMAT)

J-Star Holding Co., Ltd.
Date: Aug. 14, 2024 · CIK: 0001875016 · Accession: 0000000000-24-009308

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File numbers found in text: 333-263755

Date
August 14, 2024
Author
Jing-Bin Chiang
Form
UPLOAD
Company
J-Star Holding Co., Ltd.

Letter

August 14, 2024 Jing-Bin Chiang Chief Executive Officer J-Star Holding Co., Ltd. 7/F-1, No. 633, Sec. 2, Taiwan Blvd. Xitun District, Taichung City 407 Taiwan (R.O.C.) Re:J-Star Holding Co., Ltd. Amendment No. 20 to Registration Statement on Form F-1 Filed August 2, 2024 File No. 333-263755 Dear Jing-Bin Chiang: 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. Unless we note otherwise, any references to prior comments are to comments in our July 9, 2024 letter. Amendment No. 20 to Registration Statement on Form F-1 filed August 2, 2024 Use of Proceeds, page 49 1.We note your response to prior comment 2. Please disclose whether the amounts allocated to each purpose will be sufficient to accomplish the intended use or whether you will require additional funds. If you will require additional funds, disclose the expected source, amount and nature of the funding. For example, while you increased the percentage allocated to acquiring and investing in a production plant, the actual dollar amount you intend to devote to that purpose is substantially less than what it was in prior amendments.

Please contact Andi Carpenter at 202-551-3645 or Kevin Stertzel at 202-551-3723 if you have questions regarding comments on the financial statements and related matters. Please

August 14, 2024 Page 2 contact Thomas Jones at 202-551-3602 or Geoffrey Kruczek at 202-551-3641 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc:Lawrence S. Venick, Esq.

Show Raw Text
August 14, 2024
Jing-Bin Chiang
Chief Executive Officer
J-Star Holding Co., Ltd.
7/F-1, No. 633, Sec. 2, Taiwan Blvd.
Xitun District, Taichung City 407
Taiwan (R.O.C.)
Re:J-Star Holding Co., Ltd.
Amendment No. 20 to Registration Statement on Form F-1
Filed August 2, 2024
File No. 333-263755
Dear Jing-Bin Chiang:
            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. Unless we note otherwise,
any references to prior comments are to comments in our July 9, 2024 letter.
Amendment No. 20 to Registration Statement on Form F-1 filed August 2, 2024
Use of Proceeds, page 49
1.We note your response to prior comment 2. Please disclose whether the amounts allocated
to each purpose will be sufficient to accomplish the intended use or whether you will
require additional funds.  If you will require additional funds, disclose the expected
source, amount and nature of the funding.  For example, while you increased the
percentage allocated to acquiring and investing in a production plant, the actual dollar
amount you intend to devote to that purpose is substantially less than what it was in prior
amendments.

            Please contact Andi Carpenter at 202-551-3645 or Kevin Stertzel at 202-551-3723 if you
have questions regarding comments on the financial statements and related matters. Please

August 14, 2024
Page 2
contact Thomas Jones at 202-551-3602 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Lawrence S. Venick, Esq.