SEC Comment Letter 0000000000-23-006602 to INNEOVA Holdings Ltd (INEO)
INNEOVA Holdings Ltd
Date: June 21, 2023 · CIK: 0001933951 · Accession: 0000000000-23-006602
AI Filing Summary & Sentiment
File numbers found in text: 333-267771
Letter
United States securities and exchange commission logo June 21, 2023 Ivy Lee Chief Financial Officer SAG Holdings Ltd 14 Ang Mo Kio Street 63 Singapore 569116 Re:SAG Holdings Ltd Amendment No. 5 to Registration Statement on Form F-1 Filed June 14, 2023 File No. 333-267771 Dear Ivy Lee: 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. Unless we note otherwise, our references to prior comments are to comments in our April 7, 2023 letter. Amendment No. 5 to Registration Statement on Form F-1 Exhibit 23.1, page 1 1.Please have your auditor revise their consent to include reference to the financial statements for the year ended December 31, 2021 and correctly state the date of their audit report with respect to the financial statements for the year ended December 31, 2022.
General 2.We note recent instances of extreme stock price run-ups followed by rapid price declines and stock price volatility seemingly unrelated to company performance following a number of recent initial public offerings, particularly among companies with relatively
FirstName LastNameIvy Lee Comapany NameSAG Holdings Ltd June 21, 2023 Page 2 FirstName LastName Ivy Lee SAG Holdings Ltd June 21, 2023 Page 2 smaller public floats. Revise to include a separate risk factor addressing the potential for rapid and substantial price volatility and discuss the risks to investors when investing in stock where the price is changing rapidly. Clearly state that such volatility, including any stock-run up, may be unrelated to your actual or expected operating performance and financial condition or prospects, making it difficult for prospective investors to assess the rapidly changing value of your stock. You may contact Suying Li at 202-551-3335 or Theresa Brillant at 202-551-3307 if you have questions regarding comments on the financial statements and related matters. Please contact Scott Anderegg at 202-551-3342 or Mara Ransom at 202-551-3264 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
June 21, 2023
Ivy Lee
Chief Financial Officer
SAG Holdings Ltd
14 Ang Mo Kio Street 63
Singapore 569116
Re:SAG Holdings Ltd
Amendment No. 5 to Registration Statement on Form F-1
Filed June 14, 2023
File No. 333-267771
Dear Ivy Lee:
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. Unless we note
otherwise, our references to prior comments are to comments in our April 7, 2023 letter.
Amendment No. 5 to Registration Statement on Form F-1
Exhibit 23.1, page 1
1.Please have your auditor revise their consent to include reference to the financial
statements for the year ended December 31, 2021 and correctly state the date of their audit
report with respect to the financial statements for the year ended December 31, 2022.
General
2.We note recent instances of extreme stock price run-ups followed by rapid price declines
and stock price volatility seemingly unrelated to company performance following a
number of recent initial public offerings, particularly among companies with relatively
FirstName LastNameIvy Lee
Comapany NameSAG Holdings Ltd
June 21, 2023 Page 2
FirstName LastName
Ivy Lee
SAG Holdings Ltd
June 21, 2023
Page 2
smaller public floats. Revise to include a separate risk factor addressing the potential for
rapid and substantial price volatility and discuss the risks to investors when investing in
stock where the price is changing rapidly. Clearly state that such volatility, including any
stock-run up, may be unrelated to your actual or expected operating performance and
financial condition or prospects, making it difficult for prospective investors to assess the
rapidly changing value of your stock.
You may contact Suying Li at 202-551-3335 or Theresa Brillant at 202-551-3307 if you
have questions regarding comments on the financial statements and related matters. Please
contact Scott Anderegg at 202-551-3342 or Mara Ransom at 202-551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services