SEC Comment Letter 0000000000-23-001747 to Multi Ways Holdings Ltd (MWG) (CIK 0001941500) (MWG)
Multi Ways Holdings Ltd (MWG) (CIK 0001941500)
Date: Feb. 22, 2023 · CIK: 0001941500 · Accession: 0000000000-23-001747
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File numbers found in text: 333-269641
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United States securities and exchange commission logo
February 22, 2023
James Lim Eng Hock
Chief Executive Officer
Multi Ways Holdings Limited
3E Gul Circle
Singapore 629633
Re:Multi Ways Holdings Limited
Registration Statement on Form F-1
Filed February 8, 2023
File No. 333-269641
Dear James Lim Eng Hock:
We have reviewed your registration statement and have the following comments. In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form F-1 filed February 8, 2023
Management
Compensation of Executive Directors and Executive Officers, page 100
1.Please update your compensation disclosure to reflect the fiscal year ended December 31,
2022.
Resale Shareholders, page Alt-5
2.Disclosure provides MWE Investments will beneficially own 72.62% of the shares after
the offering. Please reconcile this with your disclosure on page 102.
FirstName LastNameJames Lim Eng Hock
Comapany NameMulti Ways Holdings Limited
February 22, 2023 Page 2
FirstName LastName
James Lim Eng Hock
Multi Ways Holdings Limited
February 22, 2023
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
You may contact Andi Carpenter at 202-551-3645 or Andrew Blume at 202-551-3254 if
you have questions regarding comments on the financial statements and related matters. Please
contact Patrick Fullem at 202-551-8337 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Jason Ye