Correspondence 0001575872-24-001011 from EPWK Holdings Ltd. (EPWK, EPWKF) (CIK 0001900720) (EPWK)
EPWK Holdings Ltd. (EPWK, EPWKF) (CIK 0001900720)
Date: Sept. 17, 2024 · CIK: 0001900720 · Accession: 0001575872-24-001011
AI Filing Summary & Sentiment
File numbers found in text: 333-269657
Referenced dates: September 10, 2024
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CORRESP
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September 17, 2024
United States Securities and Exchange Commission
Division of Corporate Finance
100 F. Street, N.E.
Washington, D.C. 20549
Attn:
Aamira Chaudhry
Doug Jones
Rucha Pandit
Lilyanna Peyser
Re:
EPWK Holdings Ltd.
Amendment No. 7 to Registration Statement on Form F-1
Filed August 12, 2024
File No. 333-269657
Ladies and Gentlemen:
EPWK Holdings Ltd. (the “Company”)
submit this letter in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) contained in its letter dated September 10, 2024, relating to the above referenced Registration Statement
on Form F-1 (“Registration Statement”). The Company is concurrently submitting an amendment to the Registration Statement
(the “Amendment No. 8”).
For the Staff’s convenience, the Staff’s
comments have been stated below in their entirety in bold, followed by the corresponding responses from the Company. Except for any page
references appearing in the headings or the Staff’s comments (which are references to the Registration Statement), all page references
herein correspond to the page of the Amendment No. 8. Capitalized terms used but not defined in this letter have the meanings ascribed
to such terms in the Amendment No. 8.
Amendment No. 7 to Registration Statement on
Form F-1 Filed August 12, 2024
Exhibit 5.1
1.
Please revise the opinion to cover the shares being registered for resale by the selling stockholders.
Response: We note the Staff’s comment
and have updated the Exhibit 5.1 opinion to cover shares being registered for resale by the selling stockholders.
We thank the Staff for its review of the foregoing.
If you have any questions regarding this matter, please do not hesitate to contact Fang Liu at VCL Law LLP at fliu@vcllegal.com or by
telephone at (703) 919-7285.
Very truly yours,
/s/ Guohua Huang
Guohua Huang
EPWK Holdings Ltd., Chief Executive Officer
cc: Fang Liu Esq., VCL Law LLP