Correspondence 0001493152-23-023892 from J-Star Holding Co., Ltd. (YMAT)
J-Star Holding Co., Ltd.
Date: July 7, 2023 · CIK: 0001875016 · Accession: 0001493152-23-023892
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File numbers found in text: 333-263755
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CORRESP
1
filename1.htm
July
7, 2023
VIA
EDGAR TRANSMISSION
Securities
and Exchange Commission
Division
of Corporation Finance
Office
of Manufacturing
Washington,
D.C. 20549
Re:
J-Star
Holding Co., Ltd. (the “Company”)
Amendment
No. 10 to Registration Statement on Form F-1
Filed
May 24, 2023
File
No. 333-263755
Dear
SEC Officers,
As
counsel for the Company and on its behalf, this letter is being submitted in response to the verbal correspondence dated June 30, 2023
from the Securities and Exchange Commission (the “Commission”) in which the staff of the Commission (the “Staff”)
commented on the above-referenced Registration Statement on Form F-1 (the “Form F-1”). For the Staff’s convenience,
the Staff’s comments have been stated below in their entirety, with the Company’s responses set out immediately underneath
those comments. Please note that all references to page numbers in the responses are references to the page numbers in a revised Form
F-1 (the “Revised F-1”), filed concurrently with the submission of this letter in response to the Staff’s comments.
Amendment
No. 11 to Registration Statement on Form F-1 filed June 14, 2023
General
1.
In response to the Staff’s verbal comment with respect to updating the relevant disclosures throughout the Form F-1, the Company
has revised and updated the relevant disclosures to the extent possible in the Revised F-1 and also updated exhibits 5.1 to 5.4 and 23.6.
2.
In response to the Staff’s comment with respect to including the Inflation Reduction Act in the Form F-1, the Company has included
the relevant disclosures in the “Regulations” section on page 120 in the Revised F-1.
Should
you have any questions relating to the foregoing or wish to discuss any aspect of the Company’s filing, please contact me at +852.5600.0188.
Very
truly yours,
/s/
Lawrence S. Venick
Lawrence
S. Venick