SEC Comment Letter 0000000000-22-013590 to ARB IOT Group Ltd (ARBB)
ARB IOT Group Ltd
Date: Dec. 16, 2022 · CIK: 0001930179 · Accession: 0000000000-22-013590
AI Filing Summary & Sentiment
File numbers found in text: 333-267697
Letter
United States securities and exchange commission logo December 16, 2022 Dato’ Sri Liew Kok Leong Chief Executive Officer ARB IOT Group Ltd No. 17-03, Q Sentral, 2A, Jalan Stesen Sentral 2 Kuala Lumpur Sentral, 50470 Kuala Lumpur Malaysia Re:ARB IOT Group Ltd Amendment No. 2 to Registration Statement on Form F-1 Filed December 5, 2022 File No. 333-267697 Dear Dato’ Sri Liew Kok Leong: 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. 2 to Form F-1 Capitalization, page 40 1.Please explain the adjustment made to the amount presented as USD pro forma retained profits. Underwriting Lock-Up Agreements, page 105 2.Please disclose the exceptions to the lock-up agreements.
FirstName LastName Dato’ Sri Liew Kok Leong Comapany NameARB IOT Group Ltd December 16, 2022 Page 2 FirstName LastName Dato’ Sri Liew Kok Leong ARB IOT Group Ltd December 16, 2022 Page 2 You may contact Melissa Walsh, Senior Staff Accountant, at 202-551-3224 or Stephen Krikorian, Accounting Branch Chief, at 202-551-3488 if you have questions regarding comments on the financial statements and related matters. Please contact Kathleen Krebs, Special Counsel, at 202-551-3350 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Kevin (Qixiang) Sun, Esq.
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United States securities and exchange commission logo
December 16, 2022
Dato’ Sri Liew Kok Leong
Chief Executive Officer
ARB IOT Group Ltd
No. 17-03, Q Sentral, 2A, Jalan Stesen Sentral 2
Kuala Lumpur Sentral, 50470 Kuala Lumpur
Malaysia
Re:ARB IOT Group Ltd
Amendment No. 2 to Registration Statement on Form F-1
Filed December 5, 2022
File No. 333-267697
Dear Dato’ Sri Liew Kok Leong:
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. 2 to Form F-1
Capitalization, page 40
1.Please explain the adjustment made to the amount presented as USD pro forma retained
profits.
Underwriting
Lock-Up Agreements, page 105
2.Please disclose the exceptions to the lock-up agreements.
FirstName LastName Dato’ Sri Liew Kok Leong
Comapany NameARB IOT Group Ltd
December 16, 2022 Page 2
FirstName LastName
Dato’ Sri Liew Kok Leong
ARB IOT Group Ltd
December 16, 2022
Page 2
You may contact Melissa Walsh, Senior Staff Accountant, at 202-551-3224 or Stephen
Krikorian, Accounting Branch Chief, at 202-551-3488 if you have questions regarding
comments on the financial statements and related matters. Please contact Kathleen Krebs,
Special Counsel, at 202-551-3350 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Kevin (Qixiang) Sun, Esq.