Correspondence 0001193125-24-218119 from Xuhang Holdings Ltd (SUNH) (CIK 0001946025)
Xuhang Holdings Ltd (SUNH) (CIK 0001946025)
Date: Sept. 12, 2024 · CIK: 0001946025 · Accession: 0001193125-24-218119
AI Filing Summary & Sentiment
File numbers found in text: 333-271029
Referenced dates: September 9, 2024
Letter
Xuhang Holdings Limited
September 12, 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. 6 to Registration Statement on Form F-1
Filed August 28, 2024
File No. 333-271029
Ladies and Gentlemen:
This letter is in response to the letter dated September 9, 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 and numbered them accordingly. Amendment No. 7 to Registration Statement on Form F-1 (“Amendment No. 7”) is being filed concurrently with the submission of this letter.
Amendment No. 6 to Registration Statement on Form F-1
Capitalization, page 70
1. It appears the “Total Shareholders’ Equity” amount in the Pro Forma column does not equal the sum of the components thereof. Please modify your presentation accordingly.
In response to the Staff’s comments, we have revised our disclosure on page 70 of the Amendment No. 7 to revise the capitalization table accordingly.
Underwriting, page 187
2. Please revise the table in this section to remove the reference to Orientiert XYZ Securities Limited as your registration statement reflects that they are no longer serving as underwriters in this offering.
In response to the Staff’s comments, we have revised our disclosure on page 187 of the Amendment No. 7 to remove the reference to Orientiert XYZ Securities Limited.
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
Show Raw Text
CORRESP 1 filename1.htm CORRESP Xuhang Holdings Limited September 12, 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. 6 to Registration Statement on Form F-1 Filed August 28, 2024 File No. 333-271029 Ladies and Gentlemen: This letter is in response to the letter dated September 9, 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 and numbered them accordingly. Amendment No. 7 to Registration Statement on Form F-1 (“Amendment No. 7”) is being filed concurrently with the submission of this letter. Amendment No. 6 to Registration Statement on Form F-1 Capitalization, page 70 1. It appears the “Total Shareholders’ Equity” amount in the Pro Forma column does not equal the sum of the components thereof. Please modify your presentation accordingly. In response to the Staff’s comments, we have revised our disclosure on page 70 of the Amendment No. 7 to revise the capitalization table accordingly. Underwriting, page 187 2. Please revise the table in this section to remove the reference to Orientiert XYZ Securities Limited as your registration statement reflects that they are no longer serving as underwriters in this offering. In response to the Staff’s comments, we have revised our disclosure on page 187 of the Amendment No. 7 to remove the reference to Orientiert XYZ Securities Limited. 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