Correspondence 0001493152-22-032605 from INNEOVA Holdings Ltd (INEO)
INNEOVA Holdings Ltd
Date: Nov. 16, 2022 · CIK: 0001933951 · Accession: 0001493152-22-032605
AI Filing Summary & Sentiment
Referenced dates: November 14, 2022
Letter
SAG Holdings Limited
Ang Mo Kio 63
Singapore
November 16, 2022
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549
Attention: Scott Anderegg
Re: SAG Holdings Limited
Amendment No. 2 to Registration Statement on Form F-1
Filed October 7, 2022
CIK No. 0001933951
Ladies and Gentlemen:
By letter dated November 14, 2022, the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) provided SAG Holdings Limited (the “Company”) with comments on the Company’s Registration Statement on Form F-1, described above.
This letter contains the Company’s responses to the Staff’s comments. Concurrently herewith, the Company is filing Amendment No. 2 to the Registration Statement on Form F-1.
Amendment No. 2 to Registration Statement submitted November 15, 2022
Exhibit 23.1, page 1
1. Please advise Audit Alliance LLP to revise their consent to include a statement acknowledging the reference of their name as an “expert” in auditing and accounting as disclosed on page 113.
We have attached an updated consent form Audit Alliance acknowledging being named as an “expert” as set forth in Exhibit 23.1.
The sale or availability for sale of substantial amounts of our Ordinary Shares…, page 21
2. Revise this risk factor to acknowledge that you are registering for resale a portion of those shares held by your Selling Shareholders in a separate prospectus, in addition to those shares being sold in this initial public offering, so that it is clear to investors that such sales may further adversely impact your market price.
Securities and Exchange Commission
Division of Corporation Finance
Attention: Scott Anderegg
Page
We have updated this risk factor as requested.
Sincerely,
SAG Holdings Limited
Show Raw Text
CORRESP
1
filename1.htm
SAG
Holdings Limited
14
Ang Mo Kio 63
Singapore
569116
November
16, 2022
VIA
EDGAR
Securities
and Exchange Commission
Division
of Corporation Finance
Washington,
D.C. 20549
Attention:
Scott Anderegg
Re:
SAG Holdings Limited
Amendment
No. 2 to Registration Statement on Form F-1
Filed
October 7, 2022
CIK
No. 0001933951
Ladies
and Gentlemen:
By
letter dated November 14, 2022, the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
provided SAG Holdings Limited (the “Company”) with comments on the Company’s Registration Statement on Form F-1, described
above.
This
letter contains the Company’s responses to the Staff’s comments. Concurrently herewith, the Company is filing Amendment No.
2 to the Registration Statement on Form F-1.
Amendment
No. 2 to Registration Statement submitted November 15, 2022
Exhibit
23.1, page 1
1. Please
advise Audit Alliance LLP to revise their consent to include a statement acknowledging the
reference of their name as an “expert” in auditing and accounting as disclosed
on page 113.
We
have attached an updated consent form Audit Alliance acknowledging being named as an “expert” as set forth in Exhibit 23.1.
The
sale or availability for sale of substantial amounts of our Ordinary Shares…, page 21
2. Revise
this risk factor to acknowledge that you are registering for resale a portion of those shares
held by your Selling Shareholders in a separate prospectus, in addition to those shares being
sold in this initial public offering, so that it is clear to investors that such sales may
further adversely impact your market price.
Securities
and Exchange Commission
Division
of Corporation Finance
Attention:
Scott Anderegg
Page
2
We
have updated this risk factor as requested.
Sincerely,
SAG Holdings Limited
/s/ Ivy Lee
By:
Ivy
Lee
Chief Financial Officer
cc:
David
L. Ficksman
R.
Joilene Wood