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SEC Comment Letter 0000000000-24-010198 to EPWK Holdings Ltd. (EPWK, EPWKF) (CIK 0001900720) (EPWK)

EPWK Holdings Ltd. (EPWK, EPWKF) (CIK 0001900720)
Date: Sept. 10, 2024 · CIK: 0001900720 · Accession: 0000000000-24-010198

Offering / Registration Process Regulatory Compliance Related Party / Governance

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File numbers found in text: 333-269657

Date
September 10, 2024
Author
September 10, 2024
Form
UPLOAD
Company
EPWK Holdings Ltd. (EPWK, EPWKF) (CIK 0001900720)

Letter

September 10, 2024 Guohua Huang Chief Executive Officer EPWK Holdings Ltd. Building #2, District A, No. 359 Chengyi Rd. The third phase of Xiamen Software Park Xiamen City, Fujian Province The People’s Republic of China, 361021 Re:EPWK Holdings Ltd. Amendment No. 7 to Registration Statement on Form F-1 Filed August 12, 2024 File No. 333-269657 Dear Guohua Huang: We have reviewed your amended registration statement and have the following comment(s). Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Amendment No. 7 to Registration Statement on Form F-1 Exhibit 5.1 1.Please revise the opinion to cover the shares being registered for resale by the selling stockholders. Please contact Rucha Pandit at 202-551-6022 or Lilyanna Peyser at 202-551-3222 with any questions. Sincerely, Division of Corporation Finance

September 10, 2024 Page 2 Office of Trade & Services cc:Fang Liu, Esq.

Show Raw Text
September 10, 2024
Guohua Huang
Chief Executive Officer
EPWK Holdings Ltd.
Building #2, District A, No. 359 Chengyi Rd.
The third phase of Xiamen Software Park
Xiamen City, Fujian Province
The People’s Republic of China, 361021
Re:EPWK Holdings Ltd.
Amendment No. 7 to Registration Statement on Form F-1
Filed August 12, 2024
File No. 333-269657
Dear Guohua Huang:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Amendment No. 7 to Registration Statement on Form F-1
Exhibit 5.1
1.Please revise the opinion to cover the shares being registered for resale by the selling
stockholders.
            Please contact Rucha Pandit at 202-551-6022 or Lilyanna Peyser at 202-551-3222 with
any questions.
Sincerely,
Division of Corporation Finance

September 10, 2024
Page 2
Office of Trade & Services
cc:Fang Liu, Esq.