SEC Comment Letter 0000000000-23-006633 to Li Bang International Corp Inc. (LBGJ) (CIK 0001896425) (LBGJ)
Li Bang International Corp Inc. (LBGJ) (CIK 0001896425)
Date: June 21, 2023 · CIK: 0001896425 · Accession: 0000000000-23-006633
AI Filing Summary & Sentiment
File numbers found in text: 333-262367
Letter
United States securities and exchange commission logo June 21, 2023 Feng Huang Chief Executive Officer Li Bang International Corp Inc. No. 190 Xizhang Road, Gushan Town Jiangyin City, Jiangsu Province People’s Republic of China Re:Li Bang International Corp Inc. Amendment No. 6 to Registration Statement on Form F-1 Filed June 1, 2023 File No. 333-262367 Dear Feng Huang: 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. Amendment No. 6 to Registration Statement on Form F-1 Dilution, page 52 1.Please revise your net tangible book value calculations to include deferred tax assets, here and on page 53. Underwriting Indemnification, page 130 2.Please clarify whether the escrow arrangement was mandated by the underwriter, and if so, whether such an arrangement is typical in similar offerings.
FirstName LastNameFeng Huang Comapany NameLi Bang International Corp Inc. June 21, 2023 Page 2 FirstName LastName Feng Huang Li Bang International Corp Inc. June 21, 2023 Page 2 You may contact Melissa Kindelan, Senior Staff Accountant, at (202) 551-3564 or Christine Dietz, Senior Staff Accountant, at (202) 551-3408 if you have questions regarding comments on the financial statements and related matters. Please contact Jeff Kauten, Staff Attorney, at (202) 551-3447 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Jason Ye
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United States securities and exchange commission logo
June 21, 2023
Feng Huang
Chief Executive Officer
Li Bang International Corp Inc.
No. 190 Xizhang Road, Gushan Town
Jiangyin City, Jiangsu Province
People’s Republic of China
Re:Li Bang International Corp Inc.
Amendment No. 6 to Registration Statement on Form F-1
Filed June 1, 2023
File No. 333-262367
Dear Feng Huang:
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.
Amendment No. 6 to Registration Statement on Form F-1
Dilution, page 52
1.Please revise your net tangible book value calculations to include deferred tax assets, here
and on page 53.
Underwriting
Indemnification, page 130
2.Please clarify whether the escrow arrangement was mandated by the underwriter, and if
so, whether such an arrangement is typical in similar offerings.
FirstName LastNameFeng Huang
Comapany NameLi Bang International Corp Inc.
June 21, 2023 Page 2
FirstName LastName
Feng Huang
Li Bang International Corp Inc.
June 21, 2023
Page 2
You may contact Melissa Kindelan, Senior Staff Accountant, at (202) 551-3564 or
Christine Dietz, Senior Staff Accountant, at (202) 551-3408 if you have questions regarding
comments on the financial statements and related matters. Please contact Jeff Kauten, Staff
Attorney, at (202) 551-3447 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Jason Ye