SEC Comment Letter 0000000000-24-002862 to Innovation Beverage Group Ltd (IBG) (CIK 0001924482) (IBG)
Innovation Beverage Group Ltd (IBG) (CIK 0001924482)
Date: March 15, 2024 · CIK: 0001924482 · Accession: 0000000000-24-002862
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File numbers found in text: 333-266965
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United States securities and exchange commission logo
March 15, 2024
Dean Huge
Chief Executive Officer
Innovation Beverage Group Ltd
29 Anvil Road
Seven Hills, NSW 2147
Australia
Re:Innovation Beverage Group Ltd
Amendment No. 22 to Registration Statement on Form F-1
File No. 333-266965
Filed March 7, 2024
Dear Dean Huge:
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.
Amendment No. 22 to Registration Statement on Form F-1
Related Party Transactions, page 95
1.Please revise this section to include the required information as of the latest practicable
date. Refer to Item 7.B of Form 20-F.
Index to Consolidated Financial Statements, page F-1
2.We note your December 31, 2022 audited financial statements are older than 12 months
at the date of this amended registration statement. Please be advised that since this is
an initial public offering of your Units with each unit consisting of one ordinary share and
one warrant, you are required to provide updated annual financial statements and related
disclosures pursuant to Item 8.A.4 of Form 20-F or, if applicable, you should provide the
representations required by Instruction 2 to Item 8.A.4 in an exhibit to the filing.
FirstName LastNameDean Huge
Comapany NameInnovation Beverage Group Ltd
March 15, 2024 Page 2
FirstName LastName
Dean Huge
Innovation Beverage Group Ltd
March 15, 2024
Page 2
Please 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