SEC Comment Letter 0000000000-23-005568 to Tungray Technologies Inc (TRSG) (CIK 0001943444) (TRSG)
Tungray Technologies Inc (TRSG) (CIK 0001943444)
Date: May 25, 2023 · CIK: 0001943444 · Accession: 0000000000-23-005568
AI Filing Summary & Sentiment
File numbers found in text: 333-270434
Letter
United States securities and exchange commission logo May 25, 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. 3 to Registration Statement on Form F-1 Filed May 19, 2023 File No. 333-270434 Dear Wanjun Yao: We have reviewed your amended registration statement and have the following comment. In our comment, 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 comment applies 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 this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our May 4, 2023 letter. Amendment No. 3 to Registration Statement on Form F-1 Consolidated Statements of Cash Flows, page F-7 1.We note your response to prior comment 1. Please clarify why you considered the settlement of the related party loan receivables that were presented as a reduction of shareholders’ equity pursuant to SAB Topic 4:G for the year ended December 31, 2021 as an investing activity. We also note that the Financing activities include distributions to owners, obtaining resources from owners as well as borrowing money and repaying amounts borrowed, or otherwise settling the obligation. Refer to ASC 230-10-45- 15 and ASC 230-10-20.
FirstName LastNameWanjun Yao Comapany NameTungray Technologies Inc. May 25, 2023 Page 2 FirstName LastName Wanjun Yao Tungray Technologies Inc. May 25, 2023 Page 2 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
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United States securities and exchange commission logo
May 25, 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. 3 to Registration Statement on Form F-1
Filed May 19, 2023
File No. 333-270434
Dear Wanjun Yao:
We have reviewed your amended registration statement and have the following
comment. In our comment, 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 comment applies 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 this comment, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our May 4, 2023 letter.
Amendment No. 3 to Registration Statement on Form F-1
Consolidated Statements of Cash Flows, page F-7
1.We note your response to prior comment 1. Please clarify why you considered the
settlement of the related party loan receivables that were presented as a reduction of
shareholders’ equity pursuant to SAB Topic 4:G for the year ended December 31, 2021 as
an investing activity. We also note that the Financing activities include distributions to
owners, obtaining resources from owners as well as borrowing money and repaying
amounts borrowed, or otherwise settling the obligation. Refer to ASC 230-10-45-
15 and ASC 230-10-20.
FirstName LastNameWanjun Yao
Comapany NameTungray Technologies Inc.
May 25, 2023 Page 2
FirstName LastName
Wanjun Yao
Tungray Technologies Inc.
May 25, 2023
Page 2
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