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SEC Comment Letter 0000000000-23-012693 to Fenbo Holdings Ltd (FEBO)

Fenbo Holdings Ltd
Date: Nov. 20, 2023 · CIK: 0001957001 · Accession: 0000000000-23-012693

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Document Type
Confidence
SEC Posture
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Reasoning

File numbers found in text: 333-274448

Date
November 20, 2023
Author
Heather Clark
Form
UPLOAD
Company
Fenbo Holdings Ltd

Letter

United States securities and exchange commission logo November 20, 2023 Li Siu Lun Allan Chief Executive Officer Fenbo Holdings Ltd Unit J, 19/F, World Tech Centre 95 How Ming Street Kwun Tong, Hong Kong Re:Fenbo Holdings Ltd Amendment No. 5 to Registration Statement on Form F-1 Filed November 20, 2023 File No. 333-274448 Dear Li Siu Lun Allan: 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. Registration Statement on Form F-1 filed November 20, 2023 Exhibits 1.We note your disclosure on page I that "in the opinion of our PRC legal counsel, Sundial Law Firm, the filing requirements under the Trial Measurements do not apply to the Company." Please revise exhibit 99.2 to have counsel clearly state their opinion that the filing requirements under the Trial Measurements do not apply to the company. 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 Alex King at 202-551-8631 or Evan Ewing at 202-551-5920 with any other questions. Sincerely,

FirstName LastName Li Siu Lun Allan Comapany NameFenbo Holdings Ltd November 20, 2023 Page 2 FirstName LastName Li Siu Lun Allan Fenbo Holdings Ltd November 20, 2023 Page 2 Division of Corporation Finance Office of Manufacturing cc: Celia Velletri

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United States securities and exchange commission logo
November 20, 2023
Li Siu Lun Allan
Chief Executive Officer
Fenbo Holdings Ltd
Unit J, 19/F, World Tech Centre
95 How Ming Street
Kwun Tong, Hong Kong
Re:Fenbo Holdings Ltd
Amendment No. 5 to Registration Statement on Form F-1
Filed November 20, 2023
File No. 333-274448
Dear Li Siu Lun Allan:
            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.
Registration Statement on Form F-1 filed November 20, 2023
Exhibits
1.We note your disclosure on page I that "in the opinion of our PRC legal counsel, Sundial
Law Firm, the filing requirements under the Trial Measurements do not apply to the
Company." Please revise exhibit 99.2 to have counsel clearly state their opinion that the
filing requirements under the Trial Measurements do not apply to the company.
            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
Alex King at 202-551-8631 or Evan Ewing at 202-551-5920 with any other questions.
Sincerely,

 FirstName LastName Li Siu Lun Allan
 Comapany NameFenbo Holdings Ltd
 November 20, 2023 Page 2
 FirstName LastName
 Li Siu Lun Allan
Fenbo Holdings Ltd
November 20, 2023
Page 2
Division of Corporation Finance
Office of Manufacturing
cc:       Celia Velletri