Correspondence 0001493152-24-033830 from JBDI Holdings Ltd (JBDI) (CIK 0001964314) (JBDI)
JBDI Holdings Ltd (JBDI) (CIK 0001964314)
Date: Aug. 26, 2024 · CIK: 0001964314 · Accession: 0001493152-24-033830
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File numbers found in text: 333-276945
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CORRESP
1
filename1.htm
August
26, 2024
VIA
EDGAR
U.S.
Securities and Exchange Commission
100
F Street, NE
Washington,
D.C., 20549
Attn:
Mr. Patrick Fullem
Re:
JBDI
Holdings Limited
Registration
Statement on Form F-1, as amended (File No. 333-276945)
Request
for Acceleration of Effectiveness
Dear
Mr. Fullem:
Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), we, the underwriter (the
“Underwriter”), hereby join in the request of JBDI Holdings Limited (the “Registrant”), for the acceleration
of the effective date of the Registrant’s Registration Statement on Form F-1 (File No. 333-276945) (as amended, the
“Registration Statement”), relating to a public offering of shares of the Registrant’s ordinary shares, US$0.0005
par value, so that the Registration Statement may be declared effective on August 26, 2024, at 2:00 p.m. Eastern Time, or as soon
thereafter as practicable. The undersigned, as the Underwriter, confirms that it is aware of its obligations under the Securities
Act.
Pursuant
to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter, who is reasonably anticipated
to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears
to be reasonable to secure adequate distribution of the preliminary prospectus.
The
undersigned confirms that it has complied with and will continue to comply with, and it has been informed or will be informed by participating
dealers that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended,
in connection with the above-referenced issue.
Very truly yours,
Wilson-Davis & Co., Inc.
/s/
Robert McBey
Name:
Robert
McBey
Title:
Chief
Executive Officer