SEC Comment Letter 0000000000-23-009487 to Primech Holdings Ltd (PMEC) (CIK 0001891944) (PMEC)
Primech Holdings Ltd (PMEC) (CIK 0001891944)
Date: Aug. 29, 2023 · CIK: 0001891944 · Accession: 0000000000-23-009487
AI Filing Summary & Sentiment
File numbers found in text: 333-264036
Letter
United States securities and exchange commission logo August 29, 2023 Ken Ho Chairman Primech Holdings Pte. Ltd. 23 Ubi Crescent Singapore 408579 Re:Primech Holdings Pte. Ltd. Amendment No. 9 to Registration Statement on Form F-1 Filed August 18, 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 February 10, 2023 letter. Amendment No. 9 to Registration Statement on Form F-1 filed August 18, 2023 Industry Overview, page 58 1.Please update the tables on pages 60, 61 and 62 to include comparable information for the periods presented through the completion of your most recent fiscal year ending March 31, 2023, to the extent possible. Item 8. Exhibits., page II-2 2.Please have counsel revise exhibit 5.1 to opine on the resale shares to be offered by your resale prospectus included in your registration statement. Additionally, state the number of each of the new ordinary shares and resale shares, respectively, being opined on in connection with the legal opinion.
FirstName LastNameKen Ho Comapany NamePrimech Holdings Pte. Ltd. August 29, 2023 Page 2 FirstName LastName Ken Ho Primech Holdings Pte. Ltd. August 29, 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
Show Raw Text
United States securities and exchange commission logo
August 29, 2023
Ken Ho
Chairman
Primech Holdings Pte. Ltd.
23 Ubi Crescent
Singapore 408579
Re:Primech Holdings Pte. Ltd.
Amendment No. 9 to Registration Statement on Form F-1
Filed August 18, 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 February 10, 2023 letter.
Amendment No. 9 to Registration Statement on Form F-1 filed August 18, 2023
Industry Overview, page 58
1.Please update the tables on pages 60, 61 and 62 to include comparable information for the
periods presented through the completion of your most recent fiscal year ending March
31, 2023, to the extent possible.
Item 8. Exhibits., page II-2
2.Please have counsel revise exhibit 5.1 to opine on the resale shares to be offered by your
resale prospectus included in your registration statement. Additionally, state the number
of each of the new ordinary shares and resale shares, respectively, being opined on in
connection with the legal opinion.
FirstName LastNameKen Ho
Comapany NamePrimech Holdings Pte. Ltd.
August 29, 2023 Page 2
FirstName LastName
Ken Ho
Primech Holdings Pte. Ltd.
August 29, 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