Correspondence 0001493152-24-023657 from J-Star Holding Co., Ltd. (YMAT)
J-Star Holding Co., Ltd.
Date: June 13, 2024 · CIK: 0001875016 · Accession: 0001493152-24-023657
AI Filing Summary & Sentiment
File numbers found in text: 333-263755
Referenced dates: March 12, 2024
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CORRESP
1
filename1.htm
June
13, 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. 18 to Registration Statement on Form F-1
Filed
March 4, 2024
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 March 12, 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. 18 to Registration Statement on Form F-1 filed March 4, 2024
Item
8 Exhibits and Financial Statement Schedules, page II-1
1.
The audited financial statements included in your registration statement are currently older than twelve months. As such, you are required
to either provide updated annual audited financial statements and related disclosures according to Item 4 of Form F-1 and Item 8.A.4
of Form 20-F or, if applicable, provide the representations required by Instruction 2 of Item 8.A.4 of Form 20-F in an exhibit to the
current registration statement. We note you previously provided representations for the year ended December 31, 2022; however, you now
need to provide representations for the year ended December 31, 2023.
Response:
In response to the Staff’s comment, the Company respectfully submit that the audited financial statements are updated to the
years ended December 31, 2023 and 2022 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