Correspondence 0001213900-23-066692 from Creative Global Technology Holdings Ltd (CGTL) (CIK 0001967822) (CGTL)
Creative Global Technology Holdings Ltd (CGTL) (CIK 0001967822)
Date: Aug. 14, 2023 · CIK: 0001967822 · Accession: 0001213900-23-066692
AI Filing Summary & Sentiment
Reasoning
Referenced dates: July 28, 2023
Letter
VIA EDGAR Division of Corporation Finance Office of Trade & Services United States Securities and Exchange Commission Re: Creative Global Technology Holdings Ltd (the “Company”) Registration Statement on Form F-1 Filed on July 19, 2023 CIK No. 0001967822
Dear Mr. Nalbantian:
On behalf of our client, Creative Global Technology Holdings Ltd (the “Company”), a company incorporated in the Cayman Islands, we are submitting to the Staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”) this letter setting forth the Company’s responses to the comment contained in the Staff’s letter dated July 28, 2023 (the “Comment Letter”) on the Company’s Registration Statement on Form F-1 filed on July 19, 2023 (the “Registration Statement”).
Concurrently with the submission of this letter, the Company is submitting via EDGAR Amendment No.1 to Registration Statement (the “Revised Registration Statement”). The Company has responded to all of the Staff’s comment by revising the Registration Statement to address the comment, or by providing an explanation if the Company has not so revised the Registration Statement. For ease of reference, each comment contained in the Comment Letter is printed below in bold, followed by the Company’s responses to such comment. All page references in the responses set forth below refer to the page numbers in the Revised Registration Statement.
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.
In response to the Staff’s comment, the Company has revised the disclosure on page 58 of the Revised Registration Statement. The underwriting discounts and commission and estimated expenses will be deducted from additional paid-in capital.
If you have any questions regarding this submission, please contact Lan Lou at (917) 661-8175 or loul@junhe.com.
Thank you again for your time and attention.
Yours sincerely,
/s/ Lan Lou
Lan Lou
Partner
Jun He Law Offices LLC
cc:
Shangzhao (“Cizar”) Hong, Director and Chief Executive Officer, Creative Global
Technology Holdings Limited
Edward Chen, Partner, Wei, Wei & Co.
Fang Liu, Partner, VCL Law LLP
Show Raw Text
CORRESP
1
filename1.htm
Suite 1919, 45 Rockefeller Plaza
630 Fifth Avenue
New York, NY 10111, USA
T: (1-737) 215-8491
F: (1-917) 672-3642
junheny@junhe.com
VIA EDGAR
August 14, 2023
Division of Corporation Finance
Office of Trade & Services
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn: Nicholas Nalbantian
Re:
Creative Global Technology Holdings Ltd (the “Company”)
Registration Statement on Form F-1
Filed on July 19, 2023
CIK No. 0001967822
Dear Mr. Nalbantian:
On behalf of our client, Creative Global Technology
Holdings Ltd (the “Company”), a company incorporated in the Cayman Islands, we are submitting to the Staff of the Division
of Corporation Finance of the Securities and Exchange Commission (the “Staff”) this letter setting forth the Company’s
responses to the comment contained in the Staff’s letter dated July 28, 2023 (the “Comment Letter”) on the Company’s
Registration Statement on Form F-1 filed on July 19, 2023 (the “Registration Statement”).
Concurrently with the submission of this letter,
the Company is submitting via EDGAR Amendment No.1 to Registration Statement (the “Revised Registration Statement”). The Company
has responded to all of the Staff’s comment by revising the Registration Statement to address the comment, or by providing an explanation
if the Company has not so revised the Registration Statement. For ease of reference, each comment contained in the Comment Letter is printed
below in bold, followed by the Company’s responses to such comment. All page references in the responses set forth below refer to
the page numbers in the Revised Registration Statement.
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.
In response to the Staff’s comment,
the Company has revised the disclosure on page 58 of the Revised Registration Statement. The underwriting discounts and commission and
estimated expenses will be deducted from additional paid-in capital.
If you have any questions regarding
this submission, please contact Lan Lou at (917) 661-8175 or loul@junhe.com.
Thank you again
for your time and attention.
Yours sincerely,
/s/ Lan Lou
Lan Lou
Partner
Jun He Law Offices LLC
cc:
Shangzhao (“Cizar”) Hong, Director and Chief Executive
Officer, Creative Global
Technology Holdings Limited
Edward Chen, Partner, Wei, Wei & Co.
Fang Liu, Partner, VCL Law LLP