SEC Comment Letter 0000000000-23-007261 to Fitell Corp (FTEL) (CIK 0001928581) (FTEL)
Fitell Corp (FTEL) (CIK 0001928581)
Date: July 7, 2023 · CIK: 0001928581 · Accession: 0000000000-23-007261
AI Filing Summary & Sentiment
File numbers found in text: 333-267778
Letter
United States securities and exchange commission logo July 7, 2023 Guy Adrian Robertson Chief Executive Officer and Director Fitell Corporation 23-25 Mangrove Lane Taren Point, NSW 2229 Australia Re:Fitell Corporation Amendment No. 5 to Registration Statement on Form F-1 Filed June 21, 2023 File No. 333-267778 Dear Guy Adrian Robertson: 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. 5 to Registration Statement on Form F-1 filed June 21, 2023 Financial Statement Schedules, page II-1 1.We note that the audited financial statements of Fitell Corporation are older than 12 months. Please explain your consideration of Item 8.A.4 of Form 20-F and the corresponding instructions which indicates that, in the case of an initial public offering, audited financial statements should generally not be older than 12 months at the time of filing. Please note that audited financial statements not older than 15 months may be permitted if you are able to represent the following: The company is not required to comply with the 12-month requirement for the age of financial statements in any other jurisdiction outside the United States and complying with the 12-month requirement is impracticable or involves undue hardship. If you meet the above criteria, please provide a
FirstName LastNameGuy Adrian Robertson Comapany NameFitell Corporation July 7, 2023 Page 2 FirstName LastName Guy Adrian Robertson Fitell Corporation July 7, 2023 Page 2 representation from management which indicates you meet the criteria and file that representation as an exhibit to the amendment to this registration statement. If you do not meet the criteria, please provide updated audited financial statements and related disclosures. You may contact Andi Carpenter at 202-551-3645 or Hugh West at 202-551-3872 if you have questions regarding comments on the financial statements and related matters. Please contact Thomas Jones at 202-551-3602 or Jay Ingram at 202-551-3397 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Mark E. Crone, Esq.
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United States securities and exchange commission logo
July 7, 2023
Guy Adrian Robertson
Chief Executive Officer and Director
Fitell Corporation
23-25 Mangrove Lane
Taren Point, NSW 2229
Australia
Re:Fitell Corporation
Amendment No. 5 to Registration Statement on Form F-1
Filed June 21, 2023
File No. 333-267778
Dear Guy Adrian Robertson:
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. 5 to Registration Statement on Form F-1 filed June 21, 2023
Financial Statement Schedules, page II-1
1.We note that the audited financial statements of Fitell Corporation are older than 12
months. Please explain your consideration of Item 8.A.4 of Form 20-F and the
corresponding instructions which indicates that, in the case of an initial public offering,
audited financial statements should generally not be older than 12 months at the time of
filing. Please note that audited financial statements not older than 15 months may be
permitted if you are able to represent the following: The company is not required to
comply with the 12-month requirement for the age of financial statements in any other
jurisdiction outside the United States and complying with the 12-month requirement is
impracticable or involves undue hardship. If you meet the above criteria, please provide a
FirstName LastNameGuy Adrian Robertson
Comapany NameFitell Corporation
July 7, 2023 Page 2
FirstName LastName
Guy Adrian Robertson
Fitell Corporation
July 7, 2023
Page 2
representation from management which indicates you meet the criteria and file that
representation as an exhibit to the amendment to this registration statement. If you do not
meet the criteria, please provide updated audited financial statements and related
disclosures.
You may contact Andi Carpenter at 202-551-3645 or Hugh West at 202-551-3872 if you
have questions regarding comments on the financial statements and related matters. Please
contact Thomas Jones at 202-551-3602 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Mark E. Crone, Esq.