Correspondence 0001213900-23-059138 from RoyaLand Co Ltd. (CIK 0001924064) (RLNDF)
RoyaLand Co Ltd. (CIK 0001924064)
Date: July 24, 2023 · CIK: 0001924064 · Accession: 0001213900-23-059138
AI Filing Summary & Sentiment
File numbers found in text: 333-273097
Referenced dates: July 10, 2023
Letter
The RoyaLand Company Ltd.
Clarendon House, 2 Church Street
Hamilton, Pembroke, HM11
Bermuda
July 24, 2023
Via EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Technology
100 F Street, N.E.
Washington, D.C. 20549
Attn: Marion Graham
Jeff Kauten
Dave Edgar
Christine Dietz
Re: The RoyaLand Co Ltd.
Registration Statement on Form F-1
Filed June 30, 2023
File No. 333-273097
Ladies and Gentlemen:
We hereby submit the responses of The RoyaLand Company Ltd. (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) set forth in the Staff’s letter, dated July 10, 2023, providing the Staff’s comments with respect to the Company’s Registration Statement on Form F-1 (the “Registration Statement”).
For the convenience of the Staff, each of the Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.
Registration Statement on Form F-1 filed June 30, 2023
Interim Condensed Consolidated Financial Statements
Interim Condensed Consolidated Statement of Operations, page F-26
1. We note your revised disclosures in response to prior comment 4. Since you have restated weighted average net loss per share for the period November 29, 2022 to December 31, 2022, please revise to label the amounts as “restated.” Also, revise to provide the disclosures required by paragraph 49 of IAS 8 in the notes to the interim condensed consolidated financial statements.
Response: We have revised the Registration Statement to update the presentation and disclosure as requested.
General
2. Please update your financial statements or include as an exhibit to the filing the necessary representations as to why such update is not necessary. Refer to Item 8.A.4 of Form 20-F and Instruction 2 thereto.
Response: We have attached as exhibit 99.6 to the Registration Statement the necessary representations as to why such update to the financial statements is not necessary.
If you would like to discuss any of the responses to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at +41 22 830 2292 or Louis A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).
Sincerely,
The RoyaLand Company Ltd.
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CORRESP
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The RoyaLand Company Ltd.
Clarendon House, 2 Church Street
Hamilton, Pembroke, HM11
Bermuda
July 24, 2023
Via EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Technology
100 F Street, N.E.
Washington, D.C. 20549
Attn:
Marion Graham
Jeff Kauten
Dave Edgar
Christine Dietz
Re:
The RoyaLand Co Ltd.
Registration Statement on Form F-1
Filed June 30, 2023
File No. 333-273097
Ladies and Gentlemen:
We hereby submit the responses of The RoyaLand Company Ltd. (the “Company”)
to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”)
set forth in the Staff’s letter, dated July 10, 2023, providing the Staff’s comments with respect to the Company’s Registration
Statement on Form F-1 (the “Registration Statement”).
For the convenience of the Staff, each of the Staff’s comments
is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise, references
in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.
Registration
Statement on Form F-1 filed June 30, 2023
Interim
Condensed Consolidated Financial Statements
Interim Condensed Consolidated Statement of Operations, page F-26
1. We note your revised disclosures in response to prior comment 4. Since you have restated weighted average net loss per share for the
period November 29, 2022 to December 31, 2022, please revise to label the amounts as “restated.” Also, revise to provide the
disclosures required by paragraph 49 of IAS 8 in the notes to the interim condensed consolidated financial statements.
Response: We have revised the Registration
Statement to update the presentation and disclosure as requested.
General
2. Please update your financial statements or include as an exhibit to the filing the necessary representations as to why such update
is not necessary. Refer to Item 8.A.4 of Form 20-F and Instruction 2 thereto.
Response: We have attached as
exhibit 99.6 to the Registration Statement the necessary representations as to why such update to the financial statements is not necessary.
If you would like to discuss any of the responses
to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at +41 22 830 2292 or
Louis A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).
Sincerely,
The RoyaLand Company Ltd.
By:
/s/ Emanuele Filiberto di Savoia
Emanuele Filiberto di Savoia
Chief Executive Officer
cc: Louis A. Bevilacqua, Esq.
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