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SEC Comment Letter 0000000000-23-013698 to Mingteng International Corp Inc. (MTEN)

Mingteng International Corp Inc.
Date: Dec. 15, 2023 · CIK: 0001948099 · Accession: 0000000000-23-013698

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File numbers found in text: 333-270953

Date
December 15, 2023
Author
Yingkai Xu
Form
UPLOAD
Company
Mingteng International Corp Inc.

Letter

United States securities and exchange commission logo December 15, 2023 Yingkai Xu Chief Executive Officer Mingteng International Corp Inc. Lvhua Village, Luoshe Town Huishan District, Wuxi Jiangsu Province, China 214189 Re:Mingteng International Corp Inc. Amendment No. 4 to Registration Statement on Form F-1 Filed December 7, 2023 File No. 333-270953 Dear Yingkai Xu: We have reviewed your amended registration statement and have the following comment(s). Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a 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 letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our December 6, 2023 letter. Amendment No. 4 to Registration Statement on Form F-1 Exhibits 1.We note your response to comment 2. Please have counsel revise Exhibit 5.1 to state that the selling shareholder's shares are legally issued, fully paid and non-assessable. Refer to Section II.B.2.h of Staff Legal Bulletin No. 19. Please contact Kevin Stertzel at 202-551-3723 or Kevin Woody at 202-551-3629 if you have questions regarding comments on the financial statements and related matters. Please contact Evan Ewing at 202-551-5920 with any other questions. Sincerely,

FirstName LastNameYingkai Xu Comapany NameMingteng International Corp Inc. December 15, 2023 Page 2 FirstName LastName Yingkai Xu Mingteng International Corp Inc. December 15, 2023 Page 2 Division of Corporation Finance Office of Manufacturing

Show Raw Text
United States securities and exchange commission logo
December 15, 2023
Yingkai Xu
Chief Executive Officer
Mingteng International Corp Inc.
Lvhua Village, Luoshe Town
Huishan District, Wuxi
Jiangsu Province, China 214189
Re:Mingteng International Corp Inc.
Amendment No. 4 to Registration Statement on Form F-1
Filed December 7, 2023
File No. 333-270953
Dear Yingkai Xu:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a 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 letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our December 6, 2023 letter.
Amendment No. 4 to Registration Statement on Form F-1
Exhibits
1.We note your response to comment 2. Please have counsel revise Exhibit 5.1 to state that
the selling shareholder's shares are legally issued, fully paid and non-assessable.  Refer to
Section II.B.2.h of Staff Legal Bulletin No. 19.
            Please contact Kevin Stertzel at 202-551-3723 or Kevin Woody at 202-551-3629 if you
have questions regarding comments on the financial statements and related matters. Please
contact Evan Ewing at 202-551-5920 with any other questions.
Sincerely,

 FirstName LastNameYingkai Xu
 Comapany NameMingteng International Corp Inc.
 December 15, 2023 Page 2
 FirstName LastName
Yingkai Xu
Mingteng International Corp Inc.
December 15, 2023
Page 2
Division of Corporation Finance
Office of Manufacturing