SEC Comment Letter 0000000000-23-009604 to DAVIS COMMODITIES Ltd (DTCK) (CIK 0001949478) (DTCK)
DAVIS COMMODITIES Ltd (DTCK) (CIK 0001949478)
Date: Aug. 30, 2023 · CIK: 0001949478 · Accession: 0000000000-23-009604
AI Filing Summary & Sentiment
File numbers found in text: 333-270427
Letter
United States securities and exchange commission logo August 30, 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. 4 to Registration Statement on Form F-1 Filed August 23, 2023 File No. 333-270427 Dear Li Peng Leck: We have reviewed your amended registration statement and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our 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 comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 6, 2023 letter. Amendment No. 4 to Registration Statement on Form F-1, Filed August 23, 2023 Cover page 1.We note your intent to register a resale transaction using a separate resale prospectus. Because you do not intend to use the resale prospectus unless and until the primary offering is complete and NASDAQ listing is approved, revise to ensure the prospectus reflects that those events have taken place. For example, revise to remove the initial public offering range and your statement that there is no public market for the Company's Ordinary Shares given that you expect a market to be available when you use this prospectus. In this regard, Instruction 2 to Item 501(b)(3) of Regulation S-K requires
FirstName LastNameLi Peng Leck Comapany NameDavis Commodities Limited August 30, 2023 Page 2 FirstName LastName Li Peng Leck Davis Commodities Limited August 30, 2023 Page 2 disclosure explaining the method by which the price will be determined and indicating the trading market and the market price of the securities as of the latest practicable date. 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
August 30, 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. 4 to Registration Statement on Form F-1
Filed August 23, 2023
File No. 333-270427
Dear Li Peng Leck:
We have reviewed your amended registration statement and have the following
comment. In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our 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 comment, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our July 6, 2023 letter.
Amendment No. 4 to Registration Statement on Form F-1, Filed August 23, 2023
Cover page
1.We note your intent to register a resale transaction using a separate resale prospectus.
Because you do not intend to use the resale prospectus unless and until the primary
offering is complete and NASDAQ listing is approved, revise to ensure the prospectus
reflects that those events have taken place. For example, revise to remove the initial public
offering range and your statement that there is no public market for the Company's
Ordinary Shares given that you expect a market to be available when you use this
prospectus. In this regard, Instruction 2 to Item 501(b)(3) of Regulation S-K requires
FirstName LastNameLi Peng Leck
Comapany NameDavis Commodities Limited
August 30, 2023 Page 2
FirstName LastName
Li Peng Leck
Davis Commodities Limited
August 30, 2023
Page 2
disclosure explaining the method by which the price will be determined and indicating the
trading market and the market price of the securities as of the latest practicable date.
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