Correspondence 0001213900-24-057035 from Li Bang International Corp Inc. (LBGJ) (CIK 0001896425) (LBGJ)
Li Bang International Corp Inc. (LBGJ) (CIK 0001896425)
Date: June 28, 2024 · CIK: 0001896425 · Accession: 0001213900-24-057035
AI Filing Summary & Sentiment
File numbers found in text: 333-262367
Referenced dates: June 24, 2024
Letter
Via Edgar Correspondence Division of Corporation Finance Office of Technology Re: Li Bang International Corporation Inc. Amendment No. 10 to Registration Statement on Form F-1 Filed June 18, 2024 File No. 333-262367
Dear Mr. Kauten:
This letter is in response to the letter dated June 24, 2024 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. 11 to the Registration Statement”) is being submitted to accompany this letter.
Amendment No. 10 to Registration Statement on Form F-1
Consolidated Statements of Cash Flows, page F-35
1) As previously requested in prior comment 3, revise to label the column for the year ended June 30, 2023 “As Restated.” A similar change should be made for the same period in the Selected Consolidated Cash Flow Data on page 19.
RESPONSE: We note the Staff’s comment, and in response thereto, respectfully advise the Staff that we have revised the disclosure on page 19, page 66 and page F-35.
Notes to Consolidated Financial Statements
Note 19 - Restatement of Cash Flow Statement, page F-57
2) We note your revisions in response to prior comment 3. Please further revise the table to include the changes in the financial statement line items, Net cash used in operating activities and Net cash used in investing activities. Refer to ASC 250-10-50-7a.
RESPONSE: We note the Staff’s comment, and in response thereto, respectfully advise the Staff that we have revised the disclosure on page F-57 (see Note 19).
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
June 28, 2024
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. 10 to Registration Statement on Form F-1
Filed June 18, 2024
File No. 333-262367
Dear Mr. Kauten:
This letter is in response to the letter dated
June 24, 2024 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. 11 to the Registration Statement”) is being submitted to accompany this letter.
Amendment No. 10 to Registration Statement
on Form F-1
Consolidated Statements of Cash Flows, page F-35
1)
As previously requested in prior comment 3, revise to label the column for the year ended June 30, 2023 “As Restated.” A similar change should be made for the same period in the Selected Consolidated Cash Flow Data on page 19.
RESPONSE: We note the Staff’s comment,
and in response thereto, respectfully advise the Staff that we have revised the disclosure on page 19, page 66 and page F-35.
Notes to Consolidated Financial Statements
Note 19 - Restatement of Cash Flow Statement,
page F-57
2)
We note your revisions in response to prior comment 3. Please further revise the table to include the changes in the financial statement line items, Net cash used in operating activities and Net cash used in investing activities. Refer to ASC 250-10-50-7a.
RESPONSE: We note the Staff’s comment,
and in response thereto, respectfully advise the Staff that we have revised the disclosure on page F-57 (see Note 19).
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