Correspondence 0001493152-24-024806 from Plutus Financial Group Ltd (PLUT) (CIK 0001933021) (PLUT)
Plutus Financial Group Ltd (PLUT) (CIK 0001933021)
Date: June 21, 2024 · CIK: 0001933021 · Accession: 0001493152-24-024806
AI Filing Summary & Sentiment
File numbers found in text: 333-276791
Referenced dates: March 5, 2024
Letter
VIA EDGAR Office of Finance Division of Corporation Finance Re: Plutus Financial Group Limited Amendment No. 1 to Registration Statement on Form F-1 Filed February 23, 2024 File No. 333-276791
Dear Ms. Bednarowski and Ms. Livingston:
We write on behalf of Plutus Financial Group Limited (the “Company”) in response to comments by the United States Securities and Exchange Commission (the “Commission”) in its letter dated March 5, 2024, commenting on Amendment No. 1 to the Company’s Registration Statement on Form F-1 filed February 23, 2024 (the “Registration Statement”).
Titling and paragraph numbering of the comments listed below corresponds to the titling and numbering used in the Commission’s comment letter.
Amendment No. 1 to Registration Statement on Form S-1
Exhibits
1. We note your revised disclosure that “[t]he validity of the Ordinary Shares to be offered by the Selling Stockholders and other certain legal matters as to Cayman Islands law will be passed upon for us by Harney Westwood & Riegels.” Please have counsel revise Exhibit 5.1 to provide the legality opinion for the ordinary shares offered by the Selling Stockholders. Refer to Section II.B.1.h of Staff Legal Bulletin No. 19.
Response: In response to this comment, the Commission’s attention is directed to paragraph 4 of the opinion letter in Exhibit 5.1, where Harney Westwood & Riegels opines that “The Sale Shares offered by the Selling Stockholders are allotted and issued and fully paid and non-assessable, and there will be no further obligation of the holders of any of the Sale Shares to make any further payment to the Company in respect of such Sale Shares.”
United States Securities and Exchange Commission
Attn: Sonia Bednarowski and Jessica Livingston
June 21, 2024
Page 2 of 2
Please feel free to contact me should you require additional information at (775) 234-5221 or jlaxague@cronelawgroup.com.
THE CRONE LAW GROUP, P.C.
By: /s/ Joe Laxague
Joe Laxague, Esq.
Show Raw Text
CORRESP
1
filename1.htm
Mark
E. Crone
Managing
Partner
mcrone@cronelawgroup.com
Joe
Laxague
Partner
jlaxague@cronelawgroup.com
VIA
EDGAR
June
21, 2024
THE
UNITED STATES SECURITIES
AND
EXCHANGE COMMISSION
Office
of Finance
Division
of Corporation Finance
Washington,
D.C. 20549
Attn:
Sonia Bednarowski and Jessica Livingston
Re:
Plutus
Financial Group Limited
Amendment
No. 1 to Registration Statement on Form F-1
Filed
February 23, 2024
File
No. 333-276791
Dear
Ms. Bednarowski and Ms. Livingston:
We
write on behalf of Plutus Financial Group Limited (the “Company”) in response to comments by the United States Securities
and Exchange Commission (the “Commission”) in its letter dated March 5, 2024, commenting on Amendment No. 1 to the Company’s
Registration Statement on Form F-1 filed February 23, 2024 (the “Registration Statement”).
Titling
and paragraph numbering of the comments listed below corresponds to the titling and numbering used in the Commission’s comment
letter.
Amendment
No. 1 to Registration Statement on Form S-1
Exhibits
1.
We note your revised disclosure that “[t]he validity of the Ordinary Shares to be offered by the Selling Stockholders and
other certain legal matters as to Cayman Islands law will be passed upon for us by Harney Westwood & Riegels.” Please have
counsel revise Exhibit 5.1 to provide the legality opinion for the ordinary shares offered by the Selling Stockholders. Refer to
Section II.B.1.h of Staff Legal Bulletin No. 19.
Response:
In response to this comment, the Commission’s attention is directed to paragraph 4 of the opinion letter in Exhibit 5.1, where
Harney Westwood & Riegels opines that “The Sale Shares offered by the Selling Stockholders are allotted and issued and fully
paid and non-assessable, and there will be no further obligation of the holders of any of the Sale Shares to make any further payment
to the Company in respect of such Sale Shares.”
United
States Securities and Exchange Commission
Attn:
Sonia Bednarowski and Jessica Livingston
June
21, 2024
Page
2 of 2
Please
feel free to contact me should you require additional information at (775) 234-5221 or jlaxague@cronelawgroup.com.
THE
CRONE LAW GROUP, P.C.
By:
/s/
Joe Laxague
Joe
Laxague, Esq.