SEC Comment Letter 0000000000-23-009854 to Innovation Beverage Group Ltd (IBG) (CIK 0001924482) (IBG)
Innovation Beverage Group Ltd (IBG) (CIK 0001924482)
Date: Sept. 6, 2023 · CIK: 0001924482 · Accession: 0000000000-23-009854
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File numbers found in text: 333-266965
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United States securities and exchange commission logo
September 6, 2023
Dean Huge
Chief Executive Officer
Innovation Beverage Group Ltd
29 Anvil Road
Seven Hills, NSW 2147
Australia
Re:Innovation Beverage Group Ltd
Amendment No. 17 to Registration Statement on Form F-1
File No. 333-266965
Filed August 29, 2023
Dear Dean Huge:
We have reviewed your amended registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.
Amendment No. 17 to Registration Statement on Form F-1
Exhibits
1.Please have counsel revise the legal opinion filed as Exhibit 5.2 to address the legality
of the unit itself. See Section II.B.1 of Staff Legal Bulletin No. 19.
FirstName LastNameDean Huge
Comapany NameInnovation Beverage Group Ltd
September 6, 2023 Page 2
FirstName LastName
Dean Huge
Innovation Beverage Group Ltd
September 6, 2023
Page 2
You may contact Beverly Singleton at 202-551-3328 or Hugh West at 202-551-3872 if
you have questions regarding comments on the financial statements and related matters. Please
contact Evan Ewing at 202-551-5920 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing