Correspondence 0001493152-24-038365 from INNEOVA Holdings Ltd (INEO)
INNEOVA Holdings Ltd
Date: Sept. 26, 2024 · CIK: 0001933951 · Accession: 0001493152-24-038365
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File numbers found in text: 333-267771
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CORRESP
1
filename1.htm
Wilson-Davis
& Co., Inc.
236
Main Street
Salt
Lake City, Utah 84101
September
26, 2024
VIA
EDGAR
Securities
and Exchange Commission
Division
of Corporate Finance
100
F Street, N.E.
Washington,
D.C. 20549
Attn:
Scott Anderegg
Re:
SAG
Holdings Limited (the “Company”)
Registration
Statement on Form F-1 (Registration No. 333-267771)
Ladies
and gentlemen:
Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission (the “Commission”) under
the Securities Act of 1933, as amended, Wilson-Davis & Co., Inc., as representative of the several underwriters, hereby joins the
request of the Company that the Commission take appropriate action to cause the above-referenced Registration Statement to become effective
at 4:30 p.m., Eastern Time, on Monday, September 30, 2024, or as soon thereafter as practicable, or at such later time as the Company
or its counsel may request via telephone call to the staff.
Pursuant
to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably
anticipated to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus
as appears to be reasonable to secure adequate distribution of the preliminary prospectus.
The
undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange
Act of 1934, as amended.
Very
truly yours,
Wilson-Davis
& Co., Inc.
By:
/s/
Robert McBey
Name:
Robert
McBey
Title:
Chief
Executive Officer
cc:
Mitchell
Goldsmith, Taft Stettinius & Hollister LLP
David
Washbush, Taft Stettinius & Hollister LLP