Correspondence 0001213900-23-096463 from Li Bang International Corp Inc. (LBGJ) (CIK 0001896425) (LBGJ)
Li Bang International Corp Inc. (LBGJ) (CIK 0001896425)
Date: Dec. 18, 2023 · CIK: 0001896425 · Accession: 0001213900-23-096463
AI Filing Summary & Sentiment
File numbers found in text: 333-262367
Referenced dates: June 21, 2022
Letter
Via Edgar Correspondence Division of Corporation Finance Office of Technology Re: Li Bang International Corporation Inc. Amendment No.6 to Registration Statement on Form F-1 Filed June 1, 2023 File No. 333-262367
Dear Mr. Kauten:
This letter is in response to the letter dated June 21, 2022 from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (“SEC”) addressed to Li Bang International Corporation Inc. (the “Company”, “we”, and “our”). For ease of reference, we have recited SEC’s comments in this response and numbered them accordingly. An amended registration statement on Form F-1 (the “Amendment No. 7 to the Registration Statement”) is being submitted to accompany this letter.
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.
RESPONSE: We note the Staff’s comment, and in response thereto, respectfully advise the Staff that we have revised the net tangible book value calculations to include deferred tax assets in the Dilution Section in the Amendment No. 7 to the Registration Statement.
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.
RESPONSE: We note the Staff’s comment, and in response thereto, respectfully advise the Staff that the escrow arrangement was mandated by the underwriter and such an arrangement is typical in similar offerings.
We hope this response has addressed all of the Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein, please contact our securities counsel William S. Rosenstadt, Esq., or Mengyi “Jason” Ye, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal or jye@orllp.legal.
Li Bang International Corporation Inc.
/s/ Huang Feng
Name: Huang Feng
Title: Chief Executive Officer
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LI BANG INTERNATIONAL CORPORATION INC.
No. 190 Xizhang Road, Gushan Town
Jiangyin City, Jiangsu Province
People’s Republic of China
December 18, 2023
Via Edgar Correspondence
Jeff Kauten
Division of Corporation Finance
Office of Technology
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C., 20549
Re:
Li Bang International Corporation Inc.
Amendment No.6 to Registration Statement on
Form F-1
Filed June 1, 2023
File No. 333-262367
Dear Mr. Kauten:
This letter is in response to the letter dated
June 21, 2022 from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (“SEC”) addressed to
Li Bang International Corporation Inc. (the “Company”, “we”, and “our”). For ease of reference, we
have recited SEC’s comments in this response and numbered them accordingly. An amended registration statement on Form F-1 (the “Amendment
No. 7 to the Registration Statement”) is being submitted to accompany this letter.
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.
RESPONSE: We note the Staff’s comment,
and in response thereto, respectfully advise the Staff that we have revised the net tangible book value calculations to include deferred
tax assets in the Dilution Section in the Amendment No. 7 to the Registration Statement.
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.
RESPONSE: We note the Staff’s comment,
and in response thereto, respectfully advise the Staff that the escrow arrangement was mandated by the underwriter and such an arrangement
is typical in similar offerings.
We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact our securities counsel William S. Rosenstadt, Esq., or Mengyi “Jason” Ye, Esq. of Ortoli Rosenstadt LLP at
wsr@orllp.legal or jye@orllp.legal.
Li Bang International Corporation Inc.
/s/ Huang Feng
Name:
Huang Feng
Title:
Chief Executive Officer