SEC Comment Letter 0000000000-23-006467 to Creative Global Technology Holdings Ltd (CGTL) (CIK 0001967822) (CGTL)
Creative Global Technology Holdings Ltd (CGTL) (CIK 0001967822)
Date: June 15, 2023 · CIK: 0001967822 · Accession: 0000000000-23-006467
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United States securities and exchange commission logo
June 15, 2023
Shangzhao Hong
Chief Executive Officer
Creative Global Technology Holdings Ltd
Unit 03, 22/F, Westin Centre
26 Hung To Road, Kwun Tong
Kowloon, Hong Kong
Re:Creative Global Technology Holdings Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted June 5, 2023
CIK No. 0001967822
Dear Shangzhao Hong:
We have reviewed your amended draft registration statement and have the following
comment. In our comment, 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 comment applies 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 this comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted June 5, 2023
PRC Related Regulations Related to this Offering, page 11
1.We note your response to comments 8 and 14 and reissue in part. We acknowledge your
new disclosure stating that according to "the legal advice" of JunHe LLP. Please clarify, if
true, whether you have received an opinion of counsel from JunHe LLP. If you have not
relied upon an opinion of counsel with respect to your conclusions, state as much and
explain why such an opinion was not obtained.
FirstName LastNameShangzhao Hong
Comapany NameCreative Global Technology Holdings Ltd
June 15, 2023 Page 2
FirstName LastName
Shangzhao Hong
Creative Global Technology Holdings Ltd
June 15, 2023
Page 2
You may contact Aamira Chaudhry at 202-551-3389 or Adam Phippen at 202-551-3336
if you have questions regarding comments on the financial statements and related
matters. Please contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-3680
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Lan Lou