SEC Comment Letter 0000000000-23-006771 to INNEOVA Holdings Ltd (INEO)
INNEOVA Holdings Ltd
Date: June 26, 2023 · CIK: 0001933951 · Accession: 0000000000-23-006771
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File numbers found in text: 333-267771
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United States securities and exchange commission logo
June 26, 2023
Ivy Lee
Chief Financial Officer
SAG Holdings Ltd
14 Ang Mo Kio Street 63
Singapore 569116
Re:SAG Holdings Ltd
Amendment No. 6 to Registration Statement on Form F-1
Filed June 23, 2023
File No. 333-267771
Dear Ivy Lee:
We have reviewed your registration statement and have the following comment. In our
comment, 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 comment applies 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 the comment, we may have additional comments.
Amendment No. 6 to Registration Statement on Form F-1
Exhibit 23.1, page 1
1.The audit report dated June 14, 2023 on page F-2 appears to cover only the most recent
year. Please have your auditor further revise their consent to include reference to their
audit report on your financial statements for the year ended December 31, 2021.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
FirstName LastNameIvy Lee
Comapany NameSAG Holdings Ltd
June 26, 2023 Page 2
FirstName LastName
Ivy Lee
SAG Holdings Ltd
June 26, 2023
Page 2
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