SEC Comment Letter 0000000000-24-000800 to Raytech Holding Ltd (RAY)
Raytech Holding Ltd
Date: Jan. 22, 2024 · CIK: 0001948443 · Accession: 0000000000-24-000800
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-275197
Letter
United States securities and exchange commission logo January 22, 2024 Tim Hoi Ching Chief Executive Officer Raytech Holding Ltd Unit 609, 6/F, Nan Fung Commercial Centre No. 19 Lam Lok Street Kowloon Bay, Hong Kong Re:Raytech Holding Ltd Amendment No. 2 to Form F-1 Filed January 18, 2024 File No. 333-275197 Dear Tim Hoi Ching: We have reviewed your amended registration statement and have the following comments. 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. Amendment No. 2 to Form F-1 Related Party Transactions, page 110 1.We note from your disclosures on pages F-23 and F-41 that you have an outstanding amount due from a director ($99,776) as of September 30, 2023. Please clarify, or revise as necessary, your statement that the amount due from a director was wholly settled in cash subsequently in July 2023. 2.Section 402 of the Sarbanes-Oxley Act of 2002 prohibits public companies from extending or maintaining credit in the form of personal loans to or for any director or executive officer. To the extent necessary, disclose the action that will be taken to ensure any applicable arrangements will be extinguished prior to the completion of the initial public offering, or tell us why this provision does not apply to the loan to Mr. Ching disclosed in this section.
FirstName LastNameTim Hoi Ching Comapany NameRaytech Holding Ltd January 22, 2024 Page 2 FirstName LastName Tim Hoi Ching Raytech Holding Ltd January 22, 2024 Page 2 Please contact Heather Clark at 202-551-3624 or Hugh West at 202-551-3872 if you have questions regarding comments on the financial statements and related matters. Please contact Jennifer Angelini at 202-551-3047 or Geoffrey Kruczek at 202-551-3641 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Arila Zhou
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United States securities and exchange commission logo
January 22, 2024
Tim Hoi Ching
Chief Executive Officer
Raytech Holding Ltd
Unit 609, 6/F, Nan Fung Commercial Centre
No. 19 Lam Lok Street
Kowloon Bay, Hong Kong
Re:Raytech Holding Ltd
Amendment No. 2 to Form F-1
Filed January 18, 2024
File No. 333-275197
Dear Tim Hoi Ching:
We have reviewed your amended registration statement and have the following
comments.
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.
Amendment No. 2 to Form F-1
Related Party Transactions, page 110
1.We note from your disclosures on pages F-23 and F-41 that you have an outstanding
amount due from a director ($99,776) as of September 30, 2023. Please clarify, or revise
as necessary, your statement that the amount due from a director was wholly settled in
cash subsequently in July 2023.
2.Section 402 of the Sarbanes-Oxley Act of 2002 prohibits public companies from
extending or maintaining credit in the form of personal loans to or for any director or
executive officer. To the extent necessary, disclose the action that will be taken to ensure
any applicable arrangements will be extinguished prior to the completion of the initial
public offering, or tell us why this provision does not apply to the loan to Mr. Ching
disclosed in this section.
FirstName LastNameTim Hoi Ching
Comapany NameRaytech Holding Ltd
January 22, 2024 Page 2
FirstName LastName
Tim Hoi Ching
Raytech Holding Ltd
January 22, 2024
Page 2
Please contact Heather Clark at 202-551-3624 or Hugh West at 202-551-3872 if you have
questions regarding comments on the financial statements and related matters. Please contact
Jennifer Angelini at 202-551-3047 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Arila Zhou