CORRESP Filing
J-Star Holding Co., Ltd.
Date: May 16, 2025 · CIK: 0001875016 · Accession: 0001641172-25-011157
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-286805
Referenced dates: May 13, 2025
Letter
VIA EDGAR TRANSMISSION Securities and Exchange Commission Division of Corporation Finance Office of Manufacturing Registration Statement on Form F-1 Filed April 29, 2025 File No. 333-286805
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 May 13, 2025 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.
Registration Statement on Form F-1 filed April 29, 2025
Customers, page 96
1. Please tell us, with a view to disclosure, the basis for highlighting your relationships with Colnago and Tecnifibre. For example, did any other company account for more revenue for the years ended December 31, 2024 and 2023 than Colnago or Tecnifibre? Did either Colnago or Technifbre account for at least 10% of the registrant's net revenue for the years ended December 31, 2024 and 2023 .
Response: In response to the Staff's comment, the Company respectfully submits that the basis for highlighting its relationship with Colnago and Tecnifibre was due to our established business relationships with both customers, our milestone with Colnago in connection with Tour de France, and the success and reputation of both companies in their respective industries. Save except for Colnago, the Company respectfully submits that there were no other company accounted for at least 10% of the net revenue for the years ended December 31, 2024 and 2023.
Exhibit 23.1, page II-4
2. Revise to update the Form F-1 file number to 333-286805, if true
Response: In response to the Staff's comment, the Company filed an updated exhibit 23.1 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
Show Raw Text
CORRESP 1 filename1.htm May 16, 2025 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 ") Registration Statement on Form F-1 Filed April 29, 2025 File No. 333-286805 Dear SEC Officers, As counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated May 13, 2025 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. Registration Statement on Form F-1 filed April 29, 2025 Customers, page 96 1. Please tell us, with a view to disclosure, the basis for highlighting your relationships with Colnago and Tecnifibre. For example, did any other company account for more revenue for the years ended December 31, 2024 and 2023 than Colnago or Tecnifibre? Did either Colnago or Technifbre account for at least 10% of the registrant's net revenue for the years ended December 31, 2024 and 2023 . Response: In response to the Staff's comment, the Company respectfully submits that the basis for highlighting its relationship with Colnago and Tecnifibre was due to our established business relationships with both customers, our milestone with Colnago in connection with Tour de France, and the success and reputation of both companies in their respective industries. Save except for Colnago, the Company respectfully submits that there were no other company accounted for at least 10% of the net revenue for the years ended December 31, 2024 and 2023. Exhibit 23.1, page II-4 2. Revise to update the Form F-1 file number to 333-286805, if true Response: In response to the Staff's comment, the Company filed an updated exhibit 23.1 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