SEC Comment Letter 0000000000-24-001032 to INNEOVA Holdings Ltd (INEO)
INNEOVA Holdings Ltd
Date: Jan. 26, 2024 · CIK: 0001933951 · Accession: 0000000000-24-001032
AI Filing Summary & Sentiment
File numbers found in text: 333-267771
Letter
United States securities and exchange commission logo January 25, 2024 Ivy Lee Chief Financial Officer SAG Holdings Ltd 14 Ang Mo Kio Street 63 Singapore 569116 Re:SAG Holdings Ltd Amendment No. 10 to Registration Statement on Form F-1 Filed January 18, 2023 File No. 333-267771 Dear Ivy Lee: We have reviewed your amended registration statement and have the following comments. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a 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 this letter, we may have additional comments. Amendment No. 10 to Registration Statement on Form F-1 Compensation of Executive Directors and Executive Officers, page 85 1.Revise to update this discussion for the fiscal year ended December 31, 2023, consistent with Item 6.B. of Form 20-F. This comment also applies to your related party transaction disclosure on page 88. Refer to Item 7.B. of Form 20-F. Index to Audited Consolidated Financial Statements, page F-1 2.Please update your financial statements in accordance with Item 8.A.4 of Form 20-F or include the representation noted in Instruction 2 to Item 8.A.4 of Form 20-F as an exhibit to your registration statement.
FirstName LastNameIvy Lee Comapany NameSAG Holdings Ltd January 25, 2024 Page 2 FirstName LastName Ivy Lee SAG Holdings Ltd January 25, 2024 Page 2 Please 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
January 25, 2024
Ivy Lee
Chief Financial Officer
SAG Holdings Ltd
14 Ang Mo Kio Street 63
Singapore 569116
Re:SAG Holdings Ltd
Amendment No. 10 to Registration Statement on Form F-1
Filed January 18, 2023
File No. 333-267771
Dear Ivy Lee:
We have reviewed your amended registration statement and have the following
comments.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a 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 this letter, we may have additional comments.
Amendment No. 10 to Registration Statement on Form F-1
Compensation of Executive Directors and Executive Officers, page 85
1.Revise to update this discussion for the fiscal year ended December 31, 2023, consistent
with Item 6.B. of Form 20-F. This comment also applies to your related party transaction
disclosure on page 88. Refer to Item 7.B. of Form 20-F.
Index to Audited Consolidated Financial Statements, page F-1
2.Please update your financial statements in accordance with Item 8.A.4 of Form 20-F or
include the representation noted in Instruction 2 to Item 8.A.4 of Form 20-F as an exhibit
to your registration statement.
FirstName LastNameIvy Lee
Comapany NameSAG Holdings Ltd
January 25, 2024 Page 2
FirstName LastName
Ivy Lee
SAG Holdings Ltd
January 25, 2024
Page 2
Please 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