Correspondence 0001213900-24-042238 from RoyaLand Co Ltd. (CIK 0001924064) (RLNDF)
RoyaLand Co Ltd. (CIK 0001924064)
Date: May 13, 2024 · CIK: 0001924064 · Accession: 0001213900-24-042238
AI Filing Summary & Sentiment
File numbers found in text: 333-273097
Referenced dates: May 9, 2024
Letter
E: Lou@bevilacquapllc.com
T: 202.869.0888 (ext. 100)
W: bevilacquapllc.com
May 13, 2024
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.
Amendment No. 5 to Registration Statement on Form F-1
Filed April 26, 2024
File No. 333-273097
Ladies and Gentlemen:
On behalf of our client, The RoyaLand Company Ltd. (the “Company”), we hereby submit the response of 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 May 9, 2024, providing the Staff’s comments with respect to the Company’s Amendment No. 5 to Registration Statement on Form F-1 (the “Registration Statement”).
For the convenience of the Staff, each of the Staff’s comments is set forth below 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.
Amendment No. 5 to Registration Statement on Form F-1
Risk Factors, page 14
1. Please add a risk factor disclosing any potential conflicts of interest that may arise from the business activities of your executive officers. Specify the amount of time they will devote to your business activities and the nature of any material conflicts of interest that may exist as a result of them working for your company on a part-time basis.
Response: In response to the Staff’s comment, we have added a risk factor titled “Most of our executive officers are part-time independent contractors and may have potential conflicts of interest because of their positions with other companies” to disclose any potential conflicts of interest that may arise from the business activities of our executive officers.
1050 Connecticut Ave., NW, Suite 500
Washington, DC 20036
PG. 2
If you would like to discuss our response to the Staff’s comment or any other matters related to the Registration Statement, please contact the undersigned at 202-869-0888 (ext. 100) or Amanda I. Hawthorne at 202-869-0888 (ext. 120).
Sincerely,
/s/ Louis A. Bevilacqua
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filename1.htm
E: Lou@bevilacquapllc.com
T: 202.869.0888 (ext. 100)
W: bevilacquapllc.com
May 13, 2024
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.
Amendment No. 5 to Registration Statement on
Form F-1
Filed April 26, 2024
File No. 333-273097
Ladies and Gentlemen:
On behalf of our client, The RoyaLand Company
Ltd. (the “Company”), we hereby submit the response of 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 May 9, 2024,
providing the Staff’s comments with respect to the Company’s Amendment No. 5 to Registration Statement on Form F-1 (the “Registration
Statement”).
For the convenience of the Staff, each of the
Staff’s comments is set forth below 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.
Amendment No. 5 to Registration Statement on
Form F-1
Risk Factors, page 14
1. Please add a risk factor disclosing any potential conflicts of interest that may arise from the business
activities of your executive officers. Specify the amount of time they will devote to your business activities and the nature of any material
conflicts of interest that may exist as a result of them working for your company on a part-time basis.
Response: In response to the
Staff’s comment, we have added a risk factor titled “Most of our executive officers are part-time independent contractors
and may have potential conflicts of interest because of their positions with other companies” to disclose any potential conflicts
of interest that may arise from the business activities of our executive officers.
1050 Connecticut Ave., NW, Suite 500
Washington, DC 20036
PG. 2
If you would like to discuss our response to the
Staff’s comment or any other matters related to the Registration Statement, please contact the undersigned at 202-869-0888 (ext.
100) or Amanda I. Hawthorne at 202-869-0888 (ext. 120).
Sincerely,
/s/ Louis A. Bevilacqua
Louis A. Bevilacqua
Bevilacqua PLLC
cc: Emanuele Filiberto di Savoia, Chief Executive Officer