SEC Comment Letter 0000000000-23-004052 to JBDI Holdings Ltd (JBDI) (CIK 0001964314) (JBDI)
JBDI Holdings Ltd (JBDI) (CIK 0001964314)
Date: April 24, 2023 · CIK: 0001964314 · Accession: 0000000000-23-004052
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United States securities and exchange commission logo April 21, 2023 Lim Chwee Poh Chief Executive Officer JBDI Holdings Limited 34 Gul Crescent Singapore 629538 Re:JBDI Holdings Limited Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted April 10, 2023 CIK No. 0001964314 Dear Lim Chwee Poh: 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 submitted April 10, 2023 Business Our Services Wastewater treatment services, page 69 1.We note your response to comment 1. Please clarify whether you own or lease the wastewater treatment plant, and revise the real property section on page 73 accordingly. Also, file the lease agreement as an exhibit to this registration statement. Related Party Transactions, page 106 2.We note your response to comment 2. Please revise to identify the related party associated with the $15,000 for accounting services charges.
FirstName LastNameLim Chwee Poh Comapany NameJBDI Holdings Limited April 21, 2023 Page 2 FirstName LastName Lim Chwee Poh JBDI Holdings Limited April 21, 2023 Page 2 You may contact Dale Welcome at (202) 551-3865 or Melissa Gilmore at (202) 551- 3777 if you have questions regarding comments on the financial statements and related matters. Please contact Patrick Fullem at (202) 551-8337 or Asia Timmons-Pierce at (202) 551- 3754 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Henry F. Schlueter, Esq.
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United States securities and exchange commission logo
April 21, 2023
Lim Chwee Poh
Chief Executive Officer
JBDI Holdings Limited
34 Gul Crescent
Singapore 629538
Re:JBDI Holdings Limited
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted April 10, 2023
CIK No. 0001964314
Dear Lim Chwee Poh:
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 submitted April 10, 2023
Business
Our Services
Wastewater treatment services, page 69
1.We note your response to comment 1. Please clarify whether you own or lease the
wastewater treatment plant, and revise the real property section on page 73 accordingly.
Also, file the lease agreement as an exhibit to this registration statement.
Related Party Transactions, page 106
2.We note your response to comment 2. Please revise to identify the related party
associated with the $15,000 for accounting services charges.
FirstName LastNameLim Chwee Poh
Comapany NameJBDI Holdings Limited
April 21, 2023 Page 2
FirstName LastName
Lim Chwee Poh
JBDI Holdings Limited
April 21, 2023
Page 2
You may contact Dale Welcome at (202) 551-3865 or Melissa Gilmore at (202) 551-
3777 if you have questions regarding comments on the financial statements and related
matters. Please contact Patrick Fullem at (202) 551-8337 or Asia Timmons-Pierce at (202) 551-
3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Henry F. Schlueter, Esq.