SEC Comment Letter 0000000000-24-010930 to INNEOVA Holdings Ltd (INEO)
INNEOVA Holdings Ltd
Date: Sept. 26, 2024 · CIK: 0001933951 · Accession: 0000000000-24-010930
AI Filing Summary & Sentiment
File numbers found in text: 333-267771
Letter
September 26, 2024 Ivy Lee Chief Financial Officer SAG Holdings Ltd 14 Ang Mo Kio Street 63 Singapore 569116 Re:SAG Holdings Ltd Amendment No. 20 to Registration Statement on Form F-1 Filed September 20, 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. 20 to Registration Statement on Form F-1 General 1.Please refer to Exhibit 5.1. Please have company counsel revise the legal opinion to cover the registered public offering and resale offering. In this regard, we note that most recent legal opinion dated June 14, 2023 is dated and doesn't cover the current offerings and specifically the resale offerings. Please revise as applicable.
September 26, 2024 Page 2 Please contact Scott Anderegg at 202-551-3342 or Donald Field at 202-551-3680 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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September 26, 2024
Ivy Lee
Chief Financial Officer
SAG Holdings Ltd
14 Ang Mo Kio Street 63
Singapore 569116
Re:SAG Holdings Ltd
Amendment No. 20 to Registration Statement on Form F-1
Filed September 20, 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. 20 to Registration Statement on Form F-1
General
1.Please refer to Exhibit 5.1. Please have company counsel revise the legal opinion to cover
the registered public offering and resale offering. In this regard, we note that most recent
legal opinion dated June 14, 2023 is dated and doesn't cover the current offerings and
specifically the resale offerings. Please revise as applicable.
September 26, 2024
Page 2
Please contact Scott Anderegg at 202-551-3342 or Donald Field at 202-551-3680 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services