SEC Comment Letter 0000000000-24-002334 to INNEOVA Holdings Ltd (INEO)
INNEOVA Holdings Ltd
Date: March 1, 2024 · CIK: 0001933951 · Accession: 0000000000-24-002334
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-267771
Letter
United States securities and exchange commission logo March 1, 2024 Ivy Lee Chief Financial Officer SAG Holdings Ltd 14 Ang Mo Kio Street 63 Singapore 569116 Re:SAG Holdings Ltd Amendment No. 12 to Registration Statement on Form F-1 Filed February 21, 2024 File No. 333-267771 Dear Ivy Lee: We have reviewed your registration statement and have the following comment. 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 12 to Form F-1 filed February 21, 2024 Related Party Transactions, page 88 1.We note that you have updated your disclosure to provide sales by related entities for the financial year ended December 31, 2023. We also note your disclosure, "[s]et forth below are related party transactions of our Company for the financial years ended December 31, 2022 and 2021." Please clarify or revise your disclosure to disclose the related party transactions to include all transaction for the financial year ended December 31, 2023. 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 March 1, 2024 Page 2 FirstName LastName Ivy Lee SAG Holdings Ltd March 1, 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
March 1, 2024
Ivy Lee
Chief Financial Officer
SAG Holdings Ltd
14 Ang Mo Kio Street 63
Singapore 569116
Re:SAG Holdings Ltd
Amendment No. 12 to Registration Statement on Form F-1
Filed February 21, 2024
File No. 333-267771
Dear Ivy Lee:
We have reviewed your registration statement and have the following comment.
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 12 to Form F-1 filed February 21, 2024
Related Party Transactions, page 88
1.We note that you have updated your disclosure to provide sales by related entities for the
financial year ended December 31, 2023. We also note your disclosure, "[s]et forth below
are related party transactions of our Company for the financial years ended December 31,
2022 and 2021." Please clarify or revise your disclosure to disclose the related party
transactions to include all transaction for the financial year ended December 31, 2023.
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
March 1, 2024 Page 2
FirstName LastName
Ivy Lee
SAG Holdings Ltd
March 1, 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