SEC Comment Letter 0000000000-24-005693 to JBDI Holdings Ltd (JBDI) (CIK 0001964314) (JBDI)
JBDI Holdings Ltd (JBDI) (CIK 0001964314)
Date: May 16, 2024 · CIK: 0001964314 · Accession: 0000000000-24-005693
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File numbers found in text: 333-276945
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United States securities and exchange commission logo
May 16, 2024
Lim Chwee Poh
Chief Executive Officer
JBDI Holdings Limited
34 Gul Crescent
Singapore 629538
Re:JBDI Holdings Limited
Amendment No. 2 to Registration Statement on Form F-1
Filed May 2, 2024
File No. 333-276945
Dear Lim Chwee Poh:
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. Unless we note otherwise,
any references to prior comments are to comments in our March 6, 2024 letter.
Amendment No. 2 to Registration Statement on Form F-1 filed May 2, 2024
Exhibits
1.Please file the final legal opinion. Currently, Exhibit 5.1 is undated and contains a number
of blanks/brackets.
2.We note you filed the Purchase and Sale Agreement as Exhibit 10.6 in response to prior
comment one. We reissue the comment in part. Please file the acquisition agreement as an
exhibit to the registration statement or tell us why you are not required to do so. Refer to
Item 601(b)(2)(i) of Regulation S-K.
FirstName LastNameLim Chwee Poh
Comapany NameJBDI Holdings Limited
May 16, 2024 Page 2
FirstName LastName
Lim Chwee Poh
JBDI Holdings Limited
May 16, 2024
Page 2
Please 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.