SEC Comment Letter 0000000000-23-002948 to Himalaya Shipping Ltd. (HSHP) (CIK 0001959455) (HSHP)
Himalaya Shipping Ltd. (HSHP) (CIK 0001959455)
Date: March 23, 2023 · CIK: 0001959455 · Accession: 0000000000-23-002948
AI Filing Summary & Sentiment
File numbers found in text: 333-270337
Letter
United States securities and exchange commission logo March 23, 2023 Herman Billung Chief Executive Officer Himalaya Shipping Ltd. S.E. Pearman Building, 2nd floor 9 Par-la-Ville Road Hamilton HM 11, Bermuda Re:Himalaya Shipping Ltd. Amendment No. 1 of Registration Statement on Form F-1 Filed March 20, 2023 File No. 333-270337 Dear Herman Billung: We have reviewed your amended 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 amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our March 16, 2023 letter. Amendment No. 1 of Registration Statement on Form F-1 Key Performance Indicators Earnings Premium, page 64 1.We note your disclosure that you estimate a Himalaya-built vessel could earn up to 70% more than a comparable conventional Capesize vessel. Please revise your disclosure to provide your basis for such estimate, including all material assumptions.
FirstName LastNameHerman Billung Comapany NameHimalaya Shipping Ltd. March 23, 2023 Page 2 FirstName LastName Herman Billung Himalaya Shipping Ltd. March 23, 2023 Page 2 You may contact Lily Dang, Staff Accountant at 202-551-3867 or Mark Wojciechowski, Staff Accountant at 202-551-3759 if you have questions regarding comments on the financial statements and related matters. Please contact Michael Purcell, Staff Attorney at 202-551-5351 or Laura Nicholson, Special Counsel at 202-551-3584 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: James McDonald
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United States securities and exchange commission logo
March 23, 2023
Herman Billung
Chief Executive Officer
Himalaya Shipping Ltd.
S.E. Pearman Building, 2nd floor
9 Par-la-Ville Road
Hamilton HM 11, Bermuda
Re:Himalaya Shipping Ltd.
Amendment No. 1 of Registration Statement on Form F-1
Filed March 20, 2023
File No. 333-270337
Dear Herman Billung:
We have reviewed your amended 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 amending your registration statement and providing the
requested information. 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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our March 16, 2023 letter.
Amendment No. 1 of Registration Statement on Form F-1
Key Performance Indicators
Earnings Premium, page 64
1.We note your disclosure that you estimate a Himalaya-built vessel could earn up to 70%
more than a comparable conventional Capesize vessel. Please revise your disclosure to
provide your basis for such estimate, including all material assumptions.
FirstName LastNameHerman Billung
Comapany NameHimalaya Shipping Ltd.
March 23, 2023 Page 2
FirstName LastName
Herman Billung
Himalaya Shipping Ltd.
March 23, 2023
Page 2
You may contact Lily Dang, Staff Accountant at 202-551-3867 or Mark Wojciechowski,
Staff Accountant at 202-551-3759 if you have questions regarding comments on the financial
statements and related matters. Please contact Michael Purcell, Staff Attorney at 202-551-5351
or Laura Nicholson, Special Counsel at 202-551-3584 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: James McDonald