SEC Comment Letter 0000000000-23-003560 to Tungray Technologies Inc (TRSG) (CIK 0001943444) (TRSG)
Tungray Technologies Inc (TRSG) (CIK 0001943444)
Date: April 10, 2023 · CIK: 0001943444 · Accession: 0000000000-23-003560
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File numbers found in text: 333-270434
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United States securities and exchange commission logo
April 10, 2023
Wanjun Yao
Chief Executive Officer
Tungray Technologies Inc.
#02-01, 31 Mandai Estate,
Innovation Place Tower 4,
Singapore 729933
Re:Tungray Technologies Inc.
Amendment No. 1 to Registration Statement on Form F-1
Filed March 30, 2023
File No. 333-270434
Dear Wanjun Yao:
We have reviewed your amended 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. Unless we note
otherwise, our references to prior comments are to comments in our March 20. 2023 letter.
Amendment No. 1 to Registration Statement on Form F-1
Consolidated Financial Statements, page F-1
1.Please update your financial statements and corresponding financial information
throughout the filing to comply with Item 8.A.4 of Form 20-F.
FirstName LastNameWanjun Yao
Comapany NameTungray Technologies Inc.
April 10, 2023 Page 2
FirstName LastName
Wanjun Yao
Tungray Technologies Inc.
April 10, 2023
Page 2
Item 8. Exhibits and Financial Statement Schedules.
23.1 Consent of Friedman LLP, an independent registered public accounting firm, page II-3
2.We note Freidman's report is dated December 16, 2022 while in their consent they said
they were dismissed as auditors on December 06, 2022. Please have Freidman LLP
correct this date or have them tell us if they engaged in audit work after the date of their
dismissal.
General
3.We note your response to prior comment 1 regarding recently published Trial Measures
by the CSCR in China. Please disclose whether you have submitted an application for
approval with the CSRC.
You may contact Joseph Cascarano, Senior Staff Accountant, at (202) 551-3376 or
Robert Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters. Please contact Kyle Wiley, Staff
Attorney, at (202) 344-5791 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Anna Jinhua Wang