SEC Comment Letter 0000000000-24-003778 to Freightos Ltd (CRGO, CRGOW) (CIK 0001927719) (CRGO)
Freightos Ltd (CRGO, CRGOW) (CIK 0001927719)
Date: April 9, 2024 · CIK: 0001927719 · Accession: 0000000000-24-003778
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo April 9, 2024 Tamara Postoj Regulatory Reporting Technical Manager M&G Investment Management Limited 10 Fenchurch Avenue London EC3M 5AG Re:M&G Investment Management Limited Freightos Limited Schedule 13D Filed by M&G Investment Management Limited Filed March 18, 2024 File No. 005-94038 Dear Tamara Postoj: We have reviewed the above-captioned filing and have the following comments. Please respond to this letter by amending the filing or by providing the requested information. If you do not believe our comments apply to your facts and circumstances or that an amendment is appropriate, please tell us why in a response letter. After reviewing any amendment to the filing and any information provided in response to these comments, we may have additional comments. Schedule 13D Filed March 18, 2024 General 1.We note the date of the event reported as requiring the filing of the Schedule 13D was February 8, 2024. Rule 13d-1(a) of Regulation 13D-G requires the filing of a Schedule 13D within five business days after the date beneficial ownership of more than five percent of a class of equity securities specified in Rule 13d-1(i)(1) was acquired. Based on the February 8, 2024 event date, the Schedule 13D submitted on March 18, 2024 was not timely filed. Please advise us why the Schedule 13D was not filed within the required five business days after the date of the acquisition. 2.We note that a Schedule 13G was previously filed on April 6, 2023 and was later amended on February 13, 2024. Please mark the check box on the cover page of this Schedule 13D indicating that the filing person is filing this schedule because of Rule 13d-1(e), Rule 13d- 1(f) or Rule 13d-1(g), or otherwise advise us of the basis for the transition from Schedule 13G to Schedule 13D.
FirstName LastNameTamara Postoj Comapany NameM&G Investment Management Limited April 9, 2024 Page 2 FirstName LastName Tamara Postoj M&G Investment Management Limited April 9, 2024 Page 2 We remind you that the filing person is responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please direct any questions to Shane Callaghan at 202-551-6977 or Nicholas Panos at 202-551-3266. Sincerely, Division of Corporation Finance Office of Mergers & Acquisitions
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United States securities and exchange commission logo
April 9, 2024
Tamara Postoj
Regulatory Reporting Technical Manager
M&G Investment Management Limited
10 Fenchurch Avenue
London EC3M 5AG
Re:M&G Investment Management Limited
Freightos Limited
Schedule 13D Filed by M&G Investment Management Limited
Filed March 18, 2024
File No. 005-94038
Dear Tamara Postoj:
We have reviewed the above-captioned filing and have the following comments. Please
respond to this letter by amending the filing or by providing the requested information. If you do
not believe our comments apply to your facts and circumstances or that an amendment is
appropriate, please tell us why in a response letter.
After reviewing any amendment to the filing and any information provided in response to
these comments, we may have additional comments.
Schedule 13D Filed March 18, 2024
General
1.We note the date of the event reported as requiring the filing of the Schedule 13D was
February 8, 2024. Rule 13d-1(a) of Regulation 13D-G requires the filing of a Schedule
13D within five business days after the date beneficial ownership of more than five
percent of a class of equity securities specified in Rule 13d-1(i)(1) was acquired. Based on
the February 8, 2024 event date, the Schedule 13D submitted on March 18, 2024 was not
timely filed. Please advise us why the Schedule 13D was not filed within the required five
business days after the date of the acquisition.
2.We note that a Schedule 13G was previously filed on April 6, 2023 and was later amended
on February 13, 2024. Please mark the check box on the cover page of this Schedule 13D
indicating that the filing person is filing this schedule because of Rule 13d-1(e), Rule 13d-
1(f) or Rule 13d-1(g), or otherwise advise us of the basis for the transition from Schedule
13G to Schedule 13D.
FirstName LastNameTamara Postoj
Comapany NameM&G Investment Management Limited
April 9, 2024 Page 2
FirstName LastName
Tamara Postoj
M&G Investment Management Limited
April 9, 2024
Page 2
We remind you that the filing person is responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please direct any questions to Shane Callaghan at 202-551-6977 or Nicholas Panos at
202-551-3266.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions