Correspondence 0001493152-24-023076 from INNEOVA Holdings Ltd (INEO)
INNEOVA Holdings Ltd
Date: June 7, 2024 · CIK: 0001933951 · Accession: 0001493152-24-023076
AI Filing Summary & Sentiment
File numbers found in text: 333-267771
Letter
SAG Holdings Limited
Ang Mo Kio Street 63
Singapore
June 7, 2024
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549
Attention: Scott Anderegg
Re: SAG Holdings Limited (the “Company”)
Amendment No. 16 to Registration Statement on Form F-1
File No. 333-267771
Ladies and Gentlemen:
We have set forth below responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission contained in its letter of June 6, 2024 with respect to the Company’s Registration Statement, as noted above.
The text of the Staff’s comments is set forth below, followed in each case by the Company’s responses. Please note that all references to page numbers in the responses are references to the page numbers in the Amendment No. 17 to the Registration Statement submitted concurrently with the submission of this letter in response to the Staff’s comments.
Consolidated Balance Sheets, page F-3
1. Please revise to present your non-controlling interest as a separate component of stockholders’ equity, distinct from the equity attributable to the controlling shareholders.
We have revised to separate the non-controlling and controlling shareholders on page F-3, as requested.
Consolidated Statements of Cash Flows, page F-6
2. It appears the “balance with related parties” line item of $2,450,000 presented in change in operating assets and liabilities includes the decrease of your dividend payable to the ultimate holding company disclosed in page Note 8 on page F-19. Please tell us your basis for presenting dividend payment in operating activities, as opposed to financing activities. Refer to ASC 230-10-45-15.
We have revised the presentation of the dividend payable under financing activities on page 40 and page F-6, in accordance with ASC 230-10-45-15.
Item 9. Undertakings, page II-2
3. Revise to provide the undertakings required by Item 512(a) of Regulation S-K.
We have revised the disclosure on page II-2 of the resale prospectus to provide the undertakings required by Item 512(a) of Regulation S-K.
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
Show Raw Text
CORRESP
1
filename1.htm
SAG
Holdings Limited
14
Ang Mo Kio Street 63
Singapore
569116
June
7, 2024
VIA
EDGAR
Securities
and Exchange Commission
Division
of Corporation Finance
Washington,
D.C. 20549
Attention:
Scott Anderegg
Re:
SAG
Holdings Limited (the “Company”)
Amendment
No. 16 to Registration Statement on Form F-1
File
No. 333-267771
Ladies
and Gentlemen:
We
have set forth below responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission contained
in its letter of June 6, 2024 with respect to the Company’s Registration Statement, as noted above.
The
text of the Staff’s comments is set forth below, followed in each case by the Company’s responses. Please note that all references
to page numbers in the responses are references to the page numbers in the Amendment No. 17 to the Registration Statement submitted concurrently
with the submission of this letter in response to the Staff’s comments.
Consolidated
Balance Sheets, page F-3
1.
Please revise to present your non-controlling interest as a separate component of stockholders’ equity, distinct from the equity
attributable to the controlling shareholders.
We
have revised to separate the non-controlling and controlling shareholders on page F-3, as requested.
Consolidated
Statements of Cash Flows, page F-6
2.
It appears the “balance with related parties” line item of $2,450,000 presented in change in operating assets and liabilities
includes the decrease of your dividend payable to the ultimate holding company disclosed in page Note 8 on page F-19. Please tell us
your basis for presenting dividend payment in operating activities, as opposed to financing activities. Refer to ASC 230-10-45-15.
We have revised the
presentation of the dividend payable under financing activities on page 40 and page F-6, in accordance with ASC
230-10-45-15.
Item
9. Undertakings, page II-2
3.
Revise to provide the undertakings required by Item 512(a) of Regulation S-K.
We
have revised the disclosure on page II-2 of the resale prospectus to provide the undertakings required by Item 512(a) of Regulation S-K.
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