Correspondence 0001193125-23-078584 from Lanvin Group Holdings Ltd (LANV, LANV-WT) (CIK 0001922097) (LANV)
Lanvin Group Holdings Ltd (LANV, LANV-WT) (CIK 0001922097)
Date: March 24, 2023 · CIK: 0001922097 · Accession: 0001193125-23-078584
AI Filing Summary & Sentiment
File numbers found in text: 333-269150
Referenced dates: March 8, 2023
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Manufacturing 100 F Street, NE Washington, D.C. 20549 March 24, 2023
Dear Messrs. Dias and Ewing:
Re:
Lanvin Group Holdings Ltd
Amendment No. 2 to Registration Statement on Form F-1
Filed February 24, 2023
File No. 333-269150
On behalf of Lanvin Group Holdings Limited (the “Company”), we submit this letter setting forth the responses of the Company to the comments provided by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in its comment letter dated March 8, 2023 (the “Comment Letter”) with respect to Amendment No. 2 to Registration Statement on Form F-1 filed with the Commission on February 24, 2023 (the “Registration Statement”). Concurrently with the filing of this letter, the Company has filed Amendment No. 3 to the Registration Statement on Form F-1 (“Amended Registration Statement”) through EDGAR.
The headings and paragraph numbers in this letter correspond to those contained in the Comment Letter and, to facilitate the Staff’s review, we have reproduced the text of the Staff’s comments in bold below. Capitalized terms used but not defined herein have the meanings given to them in the Amended Registration Statement. All references to page numbers and captions (other than those in the Staff’s comments and unless otherwise stated) correspond to the page numbers and captions in the Amended Registration Statement.
Amendment No. 2 to Registration Statement on Form F-1
Preliminary Unaudited Revenues for the Year ended December 31, 2022, page 6
1. We note that you disclose preliminary revenues for the year ended December 31, 2022 without providing any additional financial information. Since providing a single preliminary financial measure may not provide investors appropriate context, please revise your disclosure to provide additional quantitative information for fiscal year 2022. For example, if you disclose preliminary revenues for fiscal year 2022, you should also disclose preliminary net income (loss) or operating income (loss) for fiscal year 2022.
PARTNERS
Teresa Y Y Ko Robert S Ashworth Calvin C S Lai Thomas T Y Ng Arun Balasubramanian Simon J Weller* Grace Y H Huang K Tim Mak Alastair N C Mordaunt* Richard Wang Georgia K Dawson* Edward G Freeman John J H Choong Richard W Bird Daniel J French Richard J Perks Philip Q Li Matthew J O’Callaghan Bing X Guan Howie C H Farn Sarah X Su David W Yi
REGISTERED FOREIGN LAWYERS
*non-resident
Xin Liu (New York, USA)
Client Meeting Suite: 36th Floor, Two Exchange Square, Central, Hong Kong
Response: In response to the Staff’s comment, the Company has revised the disclosure on page 8 of the Amended Registration Statement to disclose the preliminary results of the cost of sales, marketing and selling expenses as well as general and administrative expenses for 2022, which the Company believes provides investors appropriate context. As the Company is still in the process of completing its audit of the financial statements for 2022, net income (loss) or operating income (loss) is currently not available with reasonable certainty.
If you have any questions regarding the Amended Registration Statement, please contact Howie Farn by phone at + 852 2913 2797 or via email at howie.farn@freshfields.com.
Yours faithfully
/s/ Freshfields Bruckhaus Deringer
Freshfields Bruckhaus Deringer
cc:
Yun Cheng, Chairman and Chief Executive Officer, Lanvin Group Holdings Limited
Kat Yu David Chan, Chief Financial Officer, Lanvin Group Holdings Limited
Roy Cheng, Chief Risk Officer, Lanvin Group Holdings Limited
Show Raw Text
CORRESP 1 filename1.htm CORRESP VIA EDGAR Mr. Eranga Dias Mr. Evan Ewing United States Securities and Exchange Commission Division of Corporation Finance Office of Manufacturing 100 F Street, NE Washington, D.C. 20549 March 24, 2023 Dear Messrs. Dias and Ewing: Re: Lanvin Group Holdings Ltd Amendment No. 2 to Registration Statement on Form F-1 Filed February 24, 2023 File No. 333-269150 On behalf of Lanvin Group Holdings Limited (the “Company”), we submit this letter setting forth the responses of the Company to the comments provided by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in its comment letter dated March 8, 2023 (the “Comment Letter”) with respect to Amendment No. 2 to Registration Statement on Form F-1 filed with the Commission on February 24, 2023 (the “Registration Statement”). Concurrently with the filing of this letter, the Company has filed Amendment No. 3 to the Registration Statement on Form F-1 (“Amended Registration Statement”) through EDGAR. The headings and paragraph numbers in this letter correspond to those contained in the Comment Letter and, to facilitate the Staff’s review, we have reproduced the text of the Staff’s comments in bold below. Capitalized terms used but not defined herein have the meanings given to them in the Amended Registration Statement. All references to page numbers and captions (other than those in the Staff’s comments and unless otherwise stated) correspond to the page numbers and captions in the Amended Registration Statement. Amendment No. 2 to Registration Statement on Form F-1 Preliminary Unaudited Revenues for the Year ended December 31, 2022, page 6 1. We note that you disclose preliminary revenues for the year ended December 31, 2022 without providing any additional financial information. Since providing a single preliminary financial measure may not provide investors appropriate context, please revise your disclosure to provide additional quantitative information for fiscal year 2022. For example, if you disclose preliminary revenues for fiscal year 2022, you should also disclose preliminary net income (loss) or operating income (loss) for fiscal year 2022. PARTNERS Teresa Y Y Ko Robert S Ashworth Calvin C S Lai Thomas T Y Ng Arun Balasubramanian Simon J Weller* Grace Y H Huang K Tim Mak Alastair N C Mordaunt* Richard Wang Georgia K Dawson* Edward G Freeman John J H Choong Richard W Bird Daniel J French Richard J Perks Philip Q Li Matthew J O’Callaghan Bing X Guan Howie C H Farn Sarah X Su David W Yi REGISTERED FOREIGN LAWYERS *non-resident Xin Liu (New York, USA) Client Meeting Suite: 36th Floor, Two Exchange Square, Central, Hong Kong Response: In response to the Staff’s comment, the Company has revised the disclosure on page 8 of the Amended Registration Statement to disclose the preliminary results of the cost of sales, marketing and selling expenses as well as general and administrative expenses for 2022, which the Company believes provides investors appropriate context. As the Company is still in the process of completing its audit of the financial statements for 2022, net income (loss) or operating income (loss) is currently not available with reasonable certainty. If you have any questions regarding the Amended Registration Statement, please contact Howie Farn by phone at + 852 2913 2797 or via email at howie.farn@freshfields.com. Yours faithfully /s/ Freshfields Bruckhaus Deringer Freshfields Bruckhaus Deringer cc: Yun Cheng, Chairman and Chief Executive Officer, Lanvin Group Holdings Limited Kat Yu David Chan, Chief Financial Officer, Lanvin Group Holdings Limited Roy Cheng, Chief Risk Officer, Lanvin Group Holdings Limited