SEC Comment Letter 0000000000-23-001393 to Primech Holdings Ltd (PMEC) (CIK 0001891944) (PMEC)
Primech Holdings Ltd (PMEC) (CIK 0001891944)
Date: Feb. 10, 2023 · CIK: 0001891944 · Accession: 0000000000-23-001393
AI Filing Summary & Sentiment
File numbers found in text: 333-264036
Letter
United States securities and exchange commission logo February 10, 2023 Ken Ho Chairman Primech Holdings Pte. Ltd. 23 Ubi Crescent Singapore 408579 Re:Primech Holdings Pte. Ltd. Amendment No. 6 to Registration Statement on Form F-1 Filed January 31, 2022 File No. 333-264036 Dear Ken Ho: We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our January 11, 2023 letter. Amendment No. 6 to Registration Statement on Form F-1 filed January 31, 2023 Capitalization, page 45 1.Please tell us your consideration of including notes payable in the calculation of total capitalization.
FirstName LastNameKen Ho Comapany NamePrimech Holdings Pte. Ltd. February 10, 2023 Page 2 FirstName LastName Ken Ho Primech Holdings Pte. Ltd. February 10, 2023 Page 2 You may contact Tony Watson at 202-551-3318 or Lyn Shenk at 202-551-3380 if you have questions regarding comments on the financial statements and related matters. Please contact Brian Fetterolf at 202-551-6613 or Erin Jaskot at 202-551-3442 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Lawrence Venick
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United States securities and exchange commission logo
February 10, 2023
Ken Ho
Chairman
Primech Holdings Pte. Ltd.
23 Ubi Crescent
Singapore 408579
Re:Primech Holdings Pte. Ltd.
Amendment No. 6 to Registration Statement on Form F-1
Filed January 31, 2022
File No. 333-264036
Dear Ken Ho:
We have reviewed your amended registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our January 11, 2023 letter.
Amendment No. 6 to Registration Statement on Form F-1 filed January 31, 2023
Capitalization, page 45
1.Please tell us your consideration of including notes payable in the calculation of total
capitalization.
FirstName LastNameKen Ho
Comapany NamePrimech Holdings Pte. Ltd.
February 10, 2023 Page 2
FirstName LastName
Ken Ho
Primech Holdings Pte. Ltd.
February 10, 2023
Page 2
You may contact Tony Watson at 202-551-3318 or Lyn Shenk at 202-551-3380 if you
have questions regarding comments on the financial statements and related matters. Please
contact Brian Fetterolf at 202-551-6613 or Erin Jaskot at 202-551-3442 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Lawrence Venick