Correspondence 0001493152-23-022179 from INNEOVA Holdings Ltd (INEO)
INNEOVA Holdings Ltd
Date: June 23, 2023 · CIK: 0001933951 · Accession: 0001493152-23-022179
AI Filing Summary & Sentiment
Referenced dates: June 21, 2023
Letter
SAG Holdings Limited
Ang Mo Kio 63
Singapore
June 23, 2023
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549
Attention: Scott Anderegg
Re: SAG Holdings Limited
Amendment No. 5 to Registration Statement on Form F-1
Filed June 14, 2023
CIK No. 0001933951
Ladies and Gentlemen:
By letter dated June 21, 2023, 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. 6 to the Registration Statement on Form F-1.
Amendment No. 5 to Registration Statement on Form F-1
Exhibit 23.1, page 1
1. Please have your auditor revise their consent to include reference to the financial statements for the year ended December 31, 2021 and correctly state the date of the audit report with respect to the financial statements for the year ended December 31, 2022.
We have filed a new Exhibit 23.1 to be responsive to the Commission’s comment.
General
2. We note recent instances of extreme stock price run-ups followed by rapid price declines and stock price volatility seemingly unrelated to company performance following a number of recent initial public offerings, particularly among companies with relatively smaller public floats. Revise to include a separate risk factor addressing the potential for rapid and substantial price volatility and discuss the risks to investors when investing in stock where the price is changing rapidly. Clearly state that such volatility, including any stock-run up, may be unrelated to your actual or expected operating performance and financial condition or prospects, making it difficult for prospective investors to assess the rapidly changing value of your stock.
Securities and Exchange Commission
Division of Corporation Finance
Attention: Scott Anderegg
Page 2
We have added a risk factor on page 21 to address the Commission’s comment.
Sincerely,
SAG Holdings Limited
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CORRESP
1
filename1.htm
SAG
Holdings Limited
14
Ang Mo Kio 63
Singapore
569116
June
23, 2023
VIA
EDGAR
Securities
and Exchange Commission
Division
of Corporation Finance
Washington,
D.C. 20549
Attention:
Scott Anderegg
Re: SAG
Holdings Limited
Amendment
No. 5 to Registration Statement on Form F-1
Filed
June 14, 2023
CIK
No. 0001933951
Ladies
and Gentlemen:
By
letter dated June 21, 2023, 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. 6 to the Registration Statement on Form F-1.
Amendment
No. 5 to Registration Statement on Form F-1
Exhibit
23.1, page 1
1. Please
have your auditor revise their consent to include reference to the financial statements for
the year ended December 31, 2021 and correctly state the date of the audit report with respect
to the financial statements for the year ended December 31, 2022.
We
have filed a new Exhibit 23.1 to be responsive to the Commission’s comment.
General
2. We
note recent instances of extreme stock price run-ups followed by rapid price declines and
stock price volatility seemingly unrelated to company performance following a number of recent
initial public offerings, particularly among companies with relatively smaller public floats.
Revise to include a separate risk factor addressing the potential for rapid and substantial
price volatility and discuss the risks to investors when investing in stock where the price
is changing rapidly. Clearly state that such volatility, including any stock-run up, may
be unrelated to your actual or expected operating performance and financial condition or
prospects, making it difficult for prospective investors to assess the rapidly changing value
of your stock.
Securities
and Exchange Commission
Division
of Corporation Finance
Attention:
Scott Anderegg
Page 2
We
have added a risk factor on page 21 to address the Commission’s comment.
Sincerely,
SAG Holdings Limited
By:
Ivy
Lee
Chief
Financial Officer
cc:
David
L. Ficksman
R.
Joilene Wood