Correspondence 0001193125-24-184007 from Xuhang Holdings Ltd (SUNH) (CIK 0001946025)
Xuhang Holdings Ltd (SUNH) (CIK 0001946025)
Date: July 24, 2024 · CIK: 0001946025 · Accession: 0001193125-24-184007
AI Filing Summary & Sentiment
File numbers found in text: 333-271029
Referenced dates: July 17, 2024
Letter
Xuhang Holdings Limited
July 24, 2024
Via EDGAR
Division of Corporation Finance
Office of Trade & Services
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C., 20549
Attention: Kate Beukenkamp
Donald Field
James Giugliano
Doug Jones
Re: Xuhang Holdings Limited
Amendment No. 4 to Registration Statement on Form F-1
Filed July 1, 2024
File No. 333-271029
Ladies and Gentlemen:
This letter is in response to the letter dated July 17, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) addressed to Xuhang Holdings Limited (the “Company,” “we,” and “our”). For ease of reference, we have recited the Commission’s comments in this response. An Amendment No. 5 to Registration Statement on Form F-1 (“Amendment No. 5”) is being filed concurrently with the submission of this letter.
Amendment No. 4 to Registration Statement on Form F-1
Exhibits
1. We note your disclosure in Note 20 - Subsequent events to the financial statements that states that you and your related entities entered into several agreements, including revolving lines of credit in the form of overdraft agreements and loans. Please revise your disclosure throughout your registration statement to discuss these agreements as applicable. Additionally, please file any agreements in compliance with Item 601(b)(10) of Regulation S-K.
In response to the Staff’s comments, we have revised our disclosure on pages 85 to 86 of the Amendment No. 5 to discuss the loan agreements disclosed in Note 20 – Subsequent Events to our audited consolidated financial statements. In addition, we have filed Exhibits 10.9 to 10.13 to the Amendment No. 5 in compliance with Item 601(b)(10) of Regulation S-K.
We appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2206.
Very truly yours,
/s/ Tianhang Xiao
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CORRESP 1 filename1.htm CORRESP Xuhang Holdings Limited July 24, 2024 Via EDGAR Division of Corporation Finance Office of Trade & Services U.S. Securities and Exchange Commission 100 F Street, NE Washington, D.C., 20549 Attention: Kate Beukenkamp Donald Field James Giugliano Doug Jones Re: Xuhang Holdings Limited Amendment No. 4 to Registration Statement on Form F-1 Filed July 1, 2024 File No. 333-271029 Ladies and Gentlemen: This letter is in response to the letter dated July 17, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) addressed to Xuhang Holdings Limited (the “Company,” “we,” and “our”). For ease of reference, we have recited the Commission’s comments in this response. An Amendment No. 5 to Registration Statement on Form F-1 (“Amendment No. 5”) is being filed concurrently with the submission of this letter. Amendment No. 4 to Registration Statement on Form F-1 Exhibits 1. We note your disclosure in Note 20 - Subsequent events to the financial statements that states that you and your related entities entered into several agreements, including revolving lines of credit in the form of overdraft agreements and loans. Please revise your disclosure throughout your registration statement to discuss these agreements as applicable. Additionally, please file any agreements in compliance with Item 601(b)(10) of Regulation S-K. In response to the Staff’s comments, we have revised our disclosure on pages 85 to 86 of the Amendment No. 5 to discuss the loan agreements disclosed in Note 20 – Subsequent Events to our audited consolidated financial statements. In addition, we have filed Exhibits 10.9 to 10.13 to the Amendment No. 5 in compliance with Item 601(b)(10) of Regulation S-K. We appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2206. Very truly yours, /s/ Tianhang Xiao Name: Tianhang Xiao Title: Chief Executive Officer cc: Ying Li, Esq. Hunter Taubman Fischer & Li LLC