Correspondence 0001493152-24-035958 from DirectBooking Technology Co., Ltd. (ZDAI)
DirectBooking Technology Co., Ltd.
Date: Sept. 12, 2024 · CIK: 0001966678 · Accession: 0001493152-24-035958
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-282018
Letter
VIA EDGAR Division of Corporation Finance Office of Real Estate & Construction Re: Primega Group Holdings Limited Registration Statement on Form F-1 Filed September 10, 2024 File No. 333-282018
Dear Sir/Madam,
Primega Group Holdings Limited (the “Company,” “we,” or “us”) hereby responds to the letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated September 11, 2024, regarding its Registration Statement on Form F-1, filed on September 10, 2024.
Concurrently with the submission of this letter, the Company is filing an amended registration statement on Form F-1 (the “Amended Registration Statement”). The Staff’s comments are repeated below in bold and are followed by the Company’s response. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Registration Statement.
Registration Statement on Form F-1 Submitted September 10, 2024
Selling Shareholders, page 62
1. We note your response to prior comment 1. Please also disclose the nature of any position, office or other material relationship that each selling shareholder has had within the past three years with any of the company’s predecessors or affiliates. See Part I, Item 9.D.1 of Form 20-F.
Response: In response to the Staff’s comment, we have revised our disclosures on page 62 of the Registration Statement accordingly.
We appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Kyle Leung, Esq., or Clement Au, Esq of CFN Lawyers LLC, at +852 3468 7093 and +852 3468 6938.
Very
truly yours,
/s/
Kan Chi Wai
Show Raw Text
CORRESP
1
filename1.htm
Primega
Group Holdings Limited
September
12, 2024
VIA
EDGAR
Mr.
Benjamin Holt
Ms.
Brigitte Lippmann
Division
of Corporation Finance
Office
of Real Estate & Construction
U.S.
Securities and Exchange Commission
100
F Street, N.E.
Washington,
DC 20549
Re:
Primega
Group Holdings Limited
Registration
Statement on Form F-1
Filed
September 10, 2024
File
No. 333-282018
Dear
Sir/Madam,
Primega
Group Holdings Limited (the “Company,” “we,” or “us”) hereby responds to the
letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”),
dated September 11, 2024, regarding its Registration Statement on Form F-1, filed on September 10, 2024.
Concurrently
with the submission of this letter, the Company is filing an amended registration statement on Form F-1 (the “Amended Registration
Statement”). The Staff’s comments are repeated below in bold and are followed by the Company’s response. Capitalized
terms used but not otherwise defined herein have the meanings set forth in the Registration Statement.
Registration
Statement on Form F-1 Submitted September 10, 2024
Selling
Shareholders, page 62
1.
We
note your response to prior comment 1. Please also disclose the nature of any position, office or other material relationship that
each selling shareholder has had within the past three years with any of the company’s predecessors or affiliates. See Part
I, Item 9.D.1 of Form 20-F.
Response:
In response to the Staff’s comment, we have revised our disclosures on page 62 of the Registration Statement accordingly.
We
appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel,
Kyle Leung, Esq., or Clement Au, Esq of CFN Lawyers LLC, at +852 3468 7093 and +852 3468 6938.
Very
truly yours,
/s/
Kan Chi Wai
Name:
Kan
Chi Wai
Title:
Chief
Executive Officer of the Company
cc:
Kyle
Leung, Esq.
Clement
Au, Esq.
CFN
Lawyers LLC