SEC Comment Letter 0000000000-23-002256 to DAVIS COMMODITIES Ltd (DTCK) (CIK 0001949478) (DTCK)
DAVIS COMMODITIES Ltd (DTCK) (CIK 0001949478)
Date: March 7, 2023 · CIK: 0001949478 · Accession: 0000000000-23-002256
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United States securities and exchange commission logo March 7, 2023 Li Peng Leck Executive Chairwoman and Executive Director Davis Commodities Limited 10 Bukit Batok Crescent #10-01, The Spire Singapore 658079 Re:Davis Commodities Limited Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted February 28, 2023 CIK No. 0001949478 Dear Li Peng Leck: We have reviewed your amended draft registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 2 to Draft Registration Statement on Form F-1, filed February 28, 2023 Use of Proceeds, page 33 1.We note your response to comment 2 and reissue in part. Please also include the interest rate and maturity of the Maxwill Foodlink bank loans. Refer to Item 3.C.4 of Form 20-F, incorporated by Item 4.a of Form F-1. Exhibits 2.We note that in previous versions of the registration statement you had included an opinion from Raja & Tann Singapore LLP regarding certain Singapore law matters, but these entries have since been removed. However, Raja & Tann Singapore LLP continues
FirstName LastNameLi Peng Leck Comapany NameDavis Commodities Limited March 7, 2023 Page 2 FirstName LastName Li Peng Leck Davis Commodities Limited March 7, 2023 Page 2 to provide advice on page 32 and is listed in the Legal Matters section on page 147. Please revise to provide a consent for this information or clarify this discrepancy. You may contact Patrick Kuhn at 202-551-3308 or Theresa Brillant at 202-551-3307 if you have questions regarding comments on the financial statements and related matters. Please contact Nicholas Nalbantian at 202-551-7470 or Mara Ransom at 202-551-3264 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Ying Li
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United States securities and exchange commission logo
March 7, 2023
Li Peng Leck
Executive Chairwoman and Executive Director
Davis Commodities Limited
10 Bukit Batok Crescent
#10-01, The Spire
Singapore 658079
Re:Davis Commodities Limited
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted February 28, 2023
CIK No. 0001949478
Dear Li Peng Leck:
We have reviewed your amended draft registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 2 to Draft Registration Statement on Form F-1, filed February 28, 2023
Use of Proceeds, page 33
1.We note your response to comment 2 and reissue in part. Please also include the interest
rate and maturity of the Maxwill Foodlink bank loans. Refer to Item 3.C.4 of Form 20-F,
incorporated by Item 4.a of Form F-1.
Exhibits
2.We note that in previous versions of the registration statement you had included an
opinion from Raja & Tann Singapore LLP regarding certain Singapore law matters, but
these entries have since been removed. However, Raja & Tann Singapore LLP continues
FirstName LastNameLi Peng Leck
Comapany NameDavis Commodities Limited
March 7, 2023 Page 2
FirstName LastName
Li Peng Leck
Davis Commodities Limited
March 7, 2023
Page 2
to provide advice on page 32 and is listed in the Legal Matters section on page 147. Please
revise to provide a consent for this information or clarify this discrepancy.
You may contact Patrick Kuhn at 202-551-3308 or Theresa Brillant at 202-551-3307 if
you have questions regarding comments on the financial statements and related matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Mara Ransom at 202-551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Ying Li