SEC Comment Letter 0000000000-23-006456 to Ryde Group Ltd (RYDE)
Ryde Group Ltd
Date: June 15, 2023 · CIK: 0001971115 · Accession: 0000000000-23-006456
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United States securities and exchange commission logo
June 15, 2023
Zou Junming Terence
Chief Executive Officer
Ryde Group Ltd
Duo Tower, 3 Fraser Street, #08-21
Singapore 189352
Re:Ryde Group Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted June 9, 2023
CIK No. 0001971115
Dear Zou Junming Terence:
We have reviewed your amended draft 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 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 comments apply 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 these comments 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 9, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Operating Metrics, page 53
1.We note your response to comment 9; however, your response suggests that metrics
associated with trips, active customers, new and/or returning, and/or driver partners are
material to you. If true, revise to disclose this information for specific historical and
comparative periods.
FirstName LastNameZou Junming Terence
Comapany NameRyde Group Ltd
June 15, 2023 Page 2
FirstName LastName
Zou Junming Terence
Ryde Group Ltd
June 15, 2023
Page 2
Factors affecting our performance
Ability to grow our revenues from ride-hailing and quick commerce, page 54
2.We note your response to comment 11 and reissue in part. In an appropriate place in your
disclosure, acknowledge that revenue attributable to mobility and quick commerce
increased only slightly from the year ended December 31, 2021 to December 31, 2022.
Additionally, explain whether and why you expect your ability to increase revenues will
be hindered by the incentives you intend to continue to offer consumers. We note your
revisions to discuss inherent challenges and risks that could hinder your ability to sustain
and further increase revenue. However, this discussion appears to be focused on external
forces, including competition and adoption by and satisfaction of consumers and driver-
partners rather than express the dynamic of how offering these incentives may negatively
impact your ability to grow revenues.
Business
Fees, page 75
3.We note your response to comment 15, including revised disclosure to discuss the fee
charged to your riders and the cash incentives provided to your driver partners. Explain
how you determine the amount and timing of the incentives you offer to your consumers.
And as reflected in our prior comment, please further revise your disclosure to discuss
how these approaches allow you to manage the challenges with growing your base of
users while also increasing revenues (e.g., by incentivizing drivers to complete a certain
number of trips you increase revenues while managing costs, or experiencing an
exponential benefit).
You may contact Tony Watson at 202-551-3318 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters. Please
contact Kate Beukenkamp at 202-551-3861 or Mara Ransom at 202-551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Meng Ding