Correspondence 0001213900-23-073248 from Primech Holdings Ltd (PMEC) (CIK 0001891944) (PMEC)
Primech Holdings Ltd (PMEC) (CIK 0001891944)
Date: Sept. 1, 2023 · CIK: 0001891944 · Accession: 0001213900-23-073248
AI Filing Summary & Sentiment
File numbers found in text: 333-264036
Referenced dates: August 29, 2023
Letter
United States Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services Primech Holdings Pte. Ltd. Amendment No. 9 to Registration Statement on Form F-1 Filed August 18, 2023 File No. 333-264036
Dear Mr. Fetterolf and Ms. Jaskot:
On behalf of our client, Primech Holdings Ltd., a Singapore company (the “Company”), we respond to the comments of the staff of the Division of Corporation Finance of the Commission (the “Staff”) with respect to the above-referenced Amendment No. 9 to Registration Statement on Form F-1 filed on August 18, 2023 (the “Registration Statement”) contained in the Staff’s letter dated August 29, 2023 (the “Comment Letter”).
The Company has publicly filed an amendment No. 10 to registration statement on Form F-1 (the “Amendment”) accompanying this response letter, which reflects the Company’s responses to the comments received by the Staff and certain updated information. For ease of reference, each comment contained in the Comment Letter is printed below and is followed by the Company’s response. All page references in the responses set forth below refer to the page numbers in the Registration Statement.
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.
Response: In response to the Staff’s comment, the Company amended the relevant disclosures on pages 60 to 63 of the Amendment.
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.
Response: In response to the Staff’s comment, the local counsel amended and refiled Exhibit 5.1 in the Amendment.
Los Angeles New York Chicago Nashville Washington, DC San Francisco Beijing Hong Kong www.loeb.com
For the United States offices, a limited liability partnership including professional corporations. For Hong Kong office, a limited liability partnership.
Please do not hesitate to contact Lawrence Venick at (310) 728-5129 or Ted Paraskevas at (917) 974-3190 of Loeb & Loeb LLP with any questions or comments regarding this letter.
Sincerely,
/s/ Loeb & Loeb LLP
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Loeb & Loeb LLP
2206-19 Jardine House
1 Connaught Road Central
Hong Kong SAR
Main +852-3923-1111
Fax +852-3923-1100
September 1, 2023
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Trade & Services
100 F Street, N.E.
Washington, D.C. 20549
Attn: Brian Fetterolf and Erin Jaskot
Re:
Primech Holdings Pte. Ltd.
Amendment No. 9 to Registration Statement on Form F-1
Filed August 18, 2023
File No. 333-264036
Dear Mr. Fetterolf and Ms. Jaskot:
On behalf of our client, Primech Holdings Ltd.,
a Singapore company (the “Company”), we respond to the comments of the staff of the Division of Corporation Finance of the
Commission (the “Staff”) with respect to the above-referenced Amendment No. 9 to Registration Statement on Form F-1 filed
on August 18, 2023 (the “Registration Statement”) contained in the Staff’s letter dated August 29, 2023 (the “Comment
Letter”).
The Company has publicly filed an amendment No.
10 to registration statement on Form F-1 (the “Amendment”) accompanying this response letter, which reflects the Company’s
responses to the comments received by the Staff and certain updated information. For ease of reference, each comment contained in the
Comment Letter is printed below and is followed by the Company’s response. All page references in the responses set forth below
refer to the page numbers in the Registration Statement.
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.
Response: In response to
the Staff’s comment, the Company amended the relevant disclosures on pages 60 to 63 of the Amendment.
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.
Response: In response to
the Staff’s comment, the local counsel amended and refiled Exhibit 5.1 in the Amendment.
Los Angeles
New York Chicago Nashville Washington, DC San Francisco
Beijing Hong Kong www.loeb.com
For the United
States offices, a limited liability partnership including professional corporations. For Hong Kong office, a limited liability
partnership.
Please do not hesitate to contact Lawrence Venick
at (310) 728-5129 or Ted Paraskevas at (917) 974-3190 of Loeb & Loeb LLP with any questions or comments regarding this letter.
Sincerely,
/s/ Loeb & Loeb LLP
Loeb & Loeb LLP
cc: Mr. Ken Ho