Correspondence 0001493152-24-001789 from J-Star Holding Co., Ltd. (YMAT)
J-Star Holding Co., Ltd.
Date: Jan. 9, 2024 · CIK: 0001875016 · Accession: 0001493152-24-001789
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-263755
Referenced dates: January 4, 2024
Letter
VIA EDGAR TRANSMISSION Securities and Exchange Commission Division of Corporation Finance Office of Manufacturing Amendment No. 16 to Registration Statement on Form F-1 Filed December 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 January 4, 2024 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. 16 to Registration Statement on Form F-1 filed December 19, 2023
Compensation of Directors and Executive Officers, page 128
1. Please update your disclosure for the fiscal-year ended December 31, 2023.
Response: In response to the Staff’s comment, the Company added the relevant disclosure on page 128 of the Revised F-1.
Related Party Transactions, page 130
2. With a view toward current disclosure, please tell us the reasons for the changes in the first paragraph of this section from “the date of this prospectus” to “June 30, 2023.”
Response: In response to the Staff’s comment, the Company amended the first paragraph of related party transaction disclosure from “the date of this prospectus” to “June 30, 2023” with the intent to cover the same period for which our auditor’s interim review report provides negative assurance which is the six months ended June 30, 2023. However, the Company has accordingly revised back to “the date of this prospectus” on page 130 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
Show Raw Text
CORRESP
1
filename1.htm
January
9, 2024
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. 16 to Registration Statement on Form F-1
Filed
December 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 January 4, 2024 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. 16 to Registration Statement on Form F-1 filed December 19, 2023
Compensation
of Directors and Executive Officers, page 128
1.
Please update your disclosure for the fiscal-year ended December 31, 2023.
Response:
In response to the Staff’s comment, the Company added the relevant disclosure on page 128 of the Revised F-1.
Related
Party Transactions, page 130
2.
With a view toward current disclosure, please tell us the reasons for the changes in the first paragraph of this section from “the
date of this prospectus” to “June 30, 2023.”
Response: In response to the Staff’s comment,
the Company amended the first paragraph of related party transaction disclosure from “the date of this prospectus” to
“June 30, 2023” with the intent to cover the same period for which our auditor’s interim review report provides negative
assurance which is the six months ended June 30, 2023. However, the Company has accordingly revised back to “the date of this prospectus”
on page 130 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