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Correspondence 0001493152-23-022614 from INNEOVA Holdings Ltd (INEO)

INNEOVA Holdings Ltd
Date: June 27, 2023 · CIK: 0001933951 · Accession: 0001493152-23-022614

AI Filing Summary & Sentiment

Referenced dates: June 26, 2023

Date
June 23, 2023
Author
SAG Holdings Limited
Form
CORRESP
Company
INNEOVA Holdings Ltd

Letter

SAG Holdings Limited

Ang Mo Kio 63

Singapore

June 27, 2023

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Washington, D.C. 20549

Attention: Scott Anderegg

Re: SAG Holdings Limited

Amendment No. 6 to Registration Statement on Form F-1

Filed June 23, 2023

CIK No. 0001933951

Ladies and Gentlemen:

By letter dated June 26, 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. 7 to the Registration Statement on Form F-1.

Amendment No. 6 to Registration Statement on Form F-1

Exhibit 23.1, page 1

1. The audit report dated June 14, 2023 on page F-2 appears to cover only the most recent year. Please have your auditor further revise their consent to include reference to their audit report on your financial statements for the year ended December 31, 2021.

We have filed the amendment to the page F-2 and a new Exhibit 23.1 to be responsive to the Commission’s comment.

Securities and Exchange Commission

Division of Corporation Finance

Attention: Scott Anderegg

Page

Sincerely,
SAG Holdings Limited

Show Raw Text
CORRESP
1
filename1.htm

SAG
Holdings Limited

14
Ang Mo Kio 63

Singapore
569116

June
27, 2023

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

Washington,
D.C. 20549

Attention:
Scott Anderegg

    Re:
    SAG Holdings Limited

    Amendment No. 6 to Registration
    Statement on Form F-1

    Filed June 23, 2023

    CIK No. 0001933951

Ladies
and Gentlemen:

By
letter dated June 26, 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. 7 to the Registration Statement on Form F-1.

Amendment
No. 6 to Registration Statement on Form F-1

Exhibit
23.1, page 1

    1.
    The audit report dated
    June 14, 2023 on page F-2 appears to cover only the most recent year. Please have your auditor further revise their consent to include
    reference to their audit report on your financial statements for the year ended December 31, 2021.

We
have filed the amendment to the page F-2 and a new Exhibit 23.1 to be responsive to the Commission’s comment.

Securities
and Exchange Commission

Division
of Corporation Finance

Attention:
Scott Anderegg

Page
2

    Sincerely,

    SAG Holdings Limited

    By:
    Ivy Lee

    Chief Financial Officer

    cc:
    David L. Ficksman

    R. Joilene Wood