Correspondence 0001185185-25-001209 from Decent Holding Inc. (DXST)
Decent Holding Inc.
Date: Sept. 15, 2025 · CIK: 0001958133 · Accession: 0001185185-25-001209
AI Filing Summary & Sentiment
Referenced dates: September 9, 2025
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CORRESP
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Decent
Holding Inc.
4th
Floor & 5th Floor North Zone, Dingxin Building
No.
106 Aokema Avenue,
Laishan
District, Yantai, Shandong Province
People’s
Republic of China 264003
September
15, 2025
VIA
EDGAR
Division
of Corporation Finance
Office
of Energy & Transportation
U.S.
Securities and Exchange Commission
100
F Street, NE
Washington,
D.C., 20549
Attn:
Timothy
S. Levenberg
Daniel
Morris
Re:
Decent Holding Inc.
Registration
Statement on Form F-1 filed on August 22, 2025
CIK
No. 0001958133
Dear
Mr. Levenberg and Mr. Morris:
This
letter is in response to the letter dated September 9, 2025 from the staff (the “Staff”) of the U.S. Securities Exchange
Commission (“SEC”) addressed to Decent Holding Inc. (the “Company”, “we”, and “our”).
Amendment no. 1 to the Company’s registration statement on Form F-1 (the “Form F-1/A”) is being filed publicly to accompany
this letter.
For
the Staff’s convenience, the Staff’s comment has been stated below in its entirety, with the Company’s response set
out immediately underneath such comment. Page references below in the Company’s responses are to the page numbers in the Form F-1/A.
Capitalized terms used but not otherwise defined herein have the meanings set forth in the Form F-1/A.
Registration
Statement on Form F-1
Principal
Shareholders, page 64
1.
Please
expand the beneficial ownership table to include ownership after taking into account securities to be sold in this offering.
RESPONSE:
We note the Staff’s comment, and in response hereto, respectfully advise the Staff that we have provided an updated disclosure
under the Section “Principal Shareholders” on page 59 of amendment no. 1 to the Company’s registration statement on
Form F-1 to expand the beneficial ownership table to include ownership after taking into account securities to be sold in this offering.
We
hope this response has addressed all of the Staff’s concerns relating to the comment letter. Should you have additional questions
regarding the information contained herein, please contact the Company’s securities counsel William S. Rosenstadt, Esq., Mengyi
“Jason” Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal, jye@orllp.legal or yly@orllp.legal.
Very truly yours,
Decent Holding Inc.
/s/
Haicheng Xu
Name:
Haicheng Xu
Title:
Chief Executive Officer and Director