Correspondence 0001493152-23-033691 from J-Star Holding Co., Ltd. (YMAT)
J-Star Holding Co., Ltd.
Date: Sept. 26, 2023 · CIK: 0001875016 · Accession: 0001493152-23-033691
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-263755
Referenced dates: September 25, 2023
Letter
VIA EDGAR TRANSMISSION Securities and Exchange Commission Division of Corporation Finance Office of Manufacturing Amendment No. 14 to Registration Statement on Form F-1 Filed September 19, 2023 File No. 333-263755
Re: J-Star Holding Co., Ltd. (the “Company”)
Dear SEC Officers,
As counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated September 25, 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. 14 to Registration Statement on Form F-1 filed September 19, 2023
General
1. You indicate on page 7 that you are not required to obtain approval or clearance from the CSRC “According to the legal opinions issued by [y]our PRC counsel, L&L-Leaven, Attorneys-at-Law.” Please revise your disclosure to clarify whether you are relying on an opinion of counsel in determining that you are not required to obtain approval or clearance from the CSRC. Please make similar revisions elsewhere that you discuss approval by the CSRC, such as your risk factors and cover page.”
Response: In response to the Staff’s comment, the Company has revised the relevant disclosure on the cover page, pages 7, 17 and 116 of 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
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CORRESP
1
filename1.htm
September
26, 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. 14 to Registration Statement on Form F-1
Filed
September 19, 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 letter dated September 25, 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. 14 to Registration Statement on Form F-1 filed September 19, 2023
General
1.
You indicate on page 7 that you are not required to obtain approval or clearance from the CSRC “According to the legal opinions
issued by [y]our PRC counsel, L&L-Leaven, Attorneys-at-Law.” Please revise your disclosure to clarify whether you are relying
on an opinion of counsel in determining that you are not required to obtain approval or clearance from the CSRC. Please make similar
revisions elsewhere that you discuss approval by the CSRC, such as your risk factors and cover page.”
Response:
In response to the Staff’s comment, the Company has revised the relevant disclosure on the cover page, pages 7, 17 and 116 of 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