Correspondence 0001493152-24-008466 from INNEOVA Holdings Ltd (INEO)
INNEOVA Holdings Ltd
Date: March 1, 2024 · CIK: 0001933951 · Accession: 0001493152-24-008466
AI Filing Summary & Sentiment
File numbers found in text: 333-267771
Referenced dates: March 1, 2024
Letter
SAG Holdings Limited
Ang Mo Kio Street 63
Singapore
March 1, 2024
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549
Attention: Thomas Jones
Re: SAG Holdings Limited
Amendment No. 12 to Registration Statement on Form F-1
Filed February 21, 2024
File No. 333-267771
Ladies and Gentlemen:
By letter dated March 1, 2024, the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) provided SAG Holdings Limited (the “Company”) with a comment on the Company’s Registration Statement on Form F-1, described above. This letter contains the Company’s response to the Staff’s comments. Concurrently herewith, the Company is filing Amendment No. 13 to Registration Statement on Form F-1. We have restated the comment and our reply below:
Related Party Transactions, page 88
1. We note that you have updated your disclosure to provide sales by related entities for the financial year ended December 31, 2023. We also note your disclosure “[s]et forth below are related party transactions for our Company for the financial years ended December 31, 2022 and 2021.” Please clarify or revise your disclosure to disclose the related party transactions to include all transactions for the financial year ended December 31, 2023.
We respectfully advise the Staff that we have clarified that the disclosure regarding related party transactions includes all transactions for the financial years ended December 31, 2023 and 2022.
If you have any questions regarding this response, please direct them to our counsel David Ficksman at 310-789-1290 or dficksman@troygould.com or Joilene Wood at 415-305-4651 or jwood@troygould.com.
Sincerely,
SAG
Holdings Limited
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SAG
Holdings Limited
14
Ang Mo Kio Street 63
Singapore
569116
March
1, 2024
VIA
EDGAR
Securities
and Exchange Commission
Division
of Corporation Finance
Washington,
D.C. 20549
Attention:
Thomas Jones
Re:
SAG
Holdings Limited
Amendment
No. 12 to Registration Statement on Form F-1
Filed
February 21, 2024
File
No. 333-267771
Ladies
and Gentlemen:
By
letter dated March 1, 2024, the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
provided SAG Holdings Limited (the “Company”) with a comment on the Company’s Registration Statement on Form F-1, described
above. This letter contains the Company’s response to the Staff’s comments. Concurrently herewith, the Company is filing
Amendment No. 13 to Registration Statement on Form F-1. We have restated the comment and our reply below:
Related
Party Transactions, page 88
1. We
note that you have updated your disclosure to provide sales by related entities for the financial
year ended December 31, 2023. We also note your disclosure “[s]et forth below are related
party transactions for our Company for the financial years ended December 31, 2022 and 2021.”
Please clarify or revise your disclosure to disclose the related party transactions to include
all transactions for the financial year ended December 31, 2023.
We
respectfully advise the Staff that we have clarified that the disclosure regarding related party transactions includes all transactions
for the financial years ended December 31, 2023 and 2022.
If
you have any questions regarding this response, please direct them to our counsel David Ficksman at 310-789-1290 or dficksman@troygould.com
or Joilene Wood at 415-305-4651 or jwood@troygould.com.
Sincerely,
SAG
Holdings Limited
/s/
Jimmy Neo
By:
Jimmy
Neo
Chief
Executive Officer & Executive Director
cc:
David
L. Ficksman
R.
Joilene Wood