SEC Comment Letter 0000000000-24-006497 to INNEOVA Holdings Ltd (INEO)
INNEOVA Holdings Ltd
Date: June 6, 2024 · CIK: 0001933951 · Accession: 0000000000-24-006497
AI Filing Summary & Sentiment
File numbers found in text: 333-267771
Letter
United States securities and exchange commission logo June 6, 2024 Ivy Lee Chief Financial Officer SAG Holdings Ltd 14 Ang Mo Kio Street 63 Singapore 569116 Re:SAG Holdings Ltd Amendment No. 16 to Registration Statement on Form F-1 Filed May 28, 2024 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. 16 to Registration Statement on Form F-1 filed May 28, 2024 Consolidated Balance Sheets, page F-3 1.Please revise to present your non-controlling interest as a separate component of stockholders' equity, distinct from the equity attributable to the controlling shareholders. Consolidated Statements of Cash Flows, page F-6 2.It appears the “balances with related parties” line item of $2,450,000 presented in change in operating assets and liabilities includes the decrease in your dividend payable to the ultimate holding company disclosed in Note 8 on page F-19. Please tell us your basis for presenting dividend payment in operating activities, as opposed to financing activities. Refer to ASC 230-10-45-15.
FirstName LastNameIvy Lee Comapany NameSAG Holdings Ltd June 6, 2024 Page 2 FirstName LastName Ivy Lee SAG Holdings Ltd June 6, 2024 Page 2 Item 9. Undertakings, page II-2 3.Revise to provide the undertakings required by Item 512(a) of Regulation S-K. 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
June 6, 2024
Ivy Lee
Chief Financial Officer
SAG Holdings Ltd
14 Ang Mo Kio Street 63
Singapore 569116
Re:SAG Holdings Ltd
Amendment No. 16 to Registration Statement on Form F-1
Filed May 28, 2024
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. 16 to Registration Statement on Form F-1 filed May 28, 2024
Consolidated Balance Sheets, page F-3
1.Please revise to present your non-controlling interest as a separate component of
stockholders' equity, distinct from the equity attributable to the controlling shareholders.
Consolidated Statements of Cash Flows, page F-6
2.It appears the “balances with related parties” line item of $2,450,000 presented in change
in operating assets and liabilities includes the decrease in your dividend payable to the
ultimate holding company disclosed in Note 8 on page F-19. Please tell us your basis for
presenting dividend payment in operating activities, as opposed to financing activities.
Refer to ASC 230-10-45-15.
FirstName LastNameIvy Lee
Comapany NameSAG Holdings Ltd
June 6, 2024 Page 2
FirstName LastName
Ivy Lee
SAG Holdings Ltd
June 6, 2024
Page 2
Item 9. Undertakings, page II-2
3.Revise to provide the undertakings required by Item 512(a) of Regulation S-K.
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