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SEC Comment Letter 0000000000-23-008083 to Creative Global Technology Holdings Ltd (CGTL) (CIK 0001967822) (CGTL)

Creative Global Technology Holdings Ltd (CGTL) (CIK 0001967822)
Date: July 28, 2023 · CIK: 0001967822 · Accession: 0000000000-23-008083

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File numbers found in text: 333-273329

Date
July 28, 2023
Author
Shangzhao Hong
Form
UPLOAD
Company
Creative Global Technology Holdings Ltd (CGTL) (CIK 0001967822)

Letter

United States securities and exchange commission logo July 28, 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 Registration Statement on Form F-1 Filed July 19, 2023 File No. 333-273329 Dear Shangzhao Hong: We have reviewed your 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 amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Registration Statement on Form F-1 Capitalization, page 58 1.Please tell us how you considered the underwriting discounts and commissions and estimated offering expense payable by you when determining as adjusted additional paid in capital. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate

FirstName LastNameShangzhao Hong Comapany NameCreative Global Technology Holdings Ltd July 28, 2023 Page 2 FirstName LastName Shangzhao Hong Creative Global Technology Holdings Ltd July 28, 2023 Page 2 time for us to review any amendment prior to the requested effective date of the registration statement. 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

Show Raw Text
United States securities and exchange commission logo
July 28, 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
Registration Statement on Form F-1
Filed July 19, 2023
File No. 333-273329
Dear Shangzhao Hong:
            We have reviewed your 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 amending your registration statement and providing the
requested information.  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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form F-1
Capitalization, page 58
1.Please tell us how you considered the underwriting discounts and commissions and
estimated offering expense payable by you when determining as adjusted additional paid
in capital.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate

 FirstName LastNameShangzhao Hong
 Comapany NameCreative Global Technology Holdings Ltd
 July 28, 2023 Page 2
 FirstName LastName
Shangzhao Hong
Creative Global Technology Holdings Ltd
July 28, 2023
Page 2
time for us to review any amendment prior to the requested effective date of the registration
statement.
            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