SEC Comment Letter 0000000000-23-012943 to Neo-Concept International Group Holdings Ltd (NCI)
Neo-Concept International Group Holdings Ltd
Date: Nov. 28, 2023 · CIK: 0001916331 · Accession: 0000000000-23-012943
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-275242
Referenced dates: November 7, 2022
Letter
United States securities and exchange commission logo November 28, 2023 Eva Yuk Yin Siu Chairlady of the Board & CEO Neo-Concept International Group Holdings Ltd 10/F, Seaview Centre No.139-141 Hoi Bun Road Kwun Tong Kowloon, Hong Kong Re:Neo-Concept International Group Holdings Ltd Amendment No. 1 to Registration Statement on Form F-1 Filed November 16, 2023 File No. 333-275242 Dear Eva Yuk Yin Siu: 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. Unless we note otherwise, any references to prior comments are to comments in our November 14, 2023 letter. Amendment No. 1 to Registration Statement on Form F-1 Cover Page 1.We note your response to prior comment 1 and reissue. Please revise to reinsert Hong Kong in the definition of China, consistent with prior comment 1 of our letter dated November 7, 2022, which asked you to revise the definition of the PRC or China to include Hong Kong and Macau. Noting that Hong Kong should be included in the definition of China, please clarify your statements on the cover page that the company and its subsidiaries have no material operations in the PRC and that the group has no operations in China. Please make sure that you use consistent terms throughout the prospectus.
FirstName LastNameEva Yuk Yin Siu Comapany NameNeo-Concept International Group Holdings Ltd November 28, 2023 Page 2 FirstName LastName Eva Yuk Yin Siu Neo-Concept International Group Holdings Ltd November 28, 2023 Page 2 Please contact Mindy Hooker at 202-551-3732 or Martin James at 202-551-3671 if you have questions regarding comments on the financial statements and related matters. Please contact Alex King at 202-551-8631 or Erin Purnell at 202-551-3454 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Henry Schlueter
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United States securities and exchange commission logo
November 28, 2023
Eva Yuk Yin Siu
Chairlady of the Board & CEO
Neo-Concept International Group Holdings Ltd
10/F, Seaview Centre
No.139-141 Hoi Bun Road
Kwun Tong
Kowloon, Hong Kong
Re:Neo-Concept International Group Holdings Ltd
Amendment No. 1 to
Registration Statement on Form F-1
Filed November 16, 2023
File No. 333-275242
Dear Eva Yuk Yin Siu:
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. Unless we note otherwise,
any references to prior comments are to comments in our November 14, 2023 letter.
Amendment No. 1 to Registration Statement on Form F-1
Cover Page
1.We note your response to prior comment 1 and reissue. Please revise to reinsert Hong
Kong in the definition of China, consistent with prior comment 1 of our letter dated
November 7, 2022, which asked you to revise the definition of the PRC or China to
include Hong Kong and Macau. Noting that Hong Kong should be included in the
definition of China, please clarify your statements on the cover page that the company and
its subsidiaries have no material operations in the PRC and that the group has no
operations in China. Please make sure that you use consistent terms throughout the
prospectus.
FirstName LastNameEva Yuk Yin Siu
Comapany NameNeo-Concept International Group Holdings Ltd
November 28, 2023 Page 2
FirstName LastName
Eva Yuk Yin Siu
Neo-Concept International Group Holdings Ltd
November 28, 2023
Page 2
Please contact Mindy Hooker at 202-551-3732 or Martin James at 202-551-3671 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alex King at 202-551-8631 or Erin Purnell at 202-551-3454 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Henry Schlueter