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SEC Comment Letter 0000000000-24-001586 to Ryde Group Ltd (RYDE)

Ryde Group Ltd
Date: Feb. 9, 2024 · CIK: 0001971115 · Accession: 0000000000-24-001586

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File numbers found in text: 333-274283

Date
February 9, 2024
Author
Zou Junming Terence
Form
UPLOAD
Company
Ryde Group Ltd

Letter

United States securities and exchange commission logo February 9, 2024 Zou Junming Terence Chief Executive Officer Ryde Group Ltd Duo Tower, 3 Fraser Street, #08-21 Singapore 189352 Re:Ryde Group Ltd Amendment No. 4 to Registration Statement on Form F-1 Filed February 6, 2024 File No. 333-274283 Dear Zou Junming Terence: We have reviewed your amended registration statement and have the following comment(s). Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our February 5, 2024 letter. Amendment No. 4 to Registration Statement on Form F-1 filed February 6, 2024 Capitalization, page 44 1.We read your response to prior comment 1. Please tell us how you determined the fair value of the 2,086,561 Class A Ordinary Shares issued to consultants and 1,131,715 Class A Ordinary Shares issued to your employees pursuant to the Scheme and the reasons for any differences between the recent valuations of your common stock leading up to the IPO and the estimated offering price. Also, please tell us your consideration of disclosing how you accounted for the 2,086,561 Class A Ordinary Shares issued to consultants and 1,131,715 Class A Ordinary Shares issued to your employees in your Capitalization Table.

FirstName LastNameZou Junming Terence Comapany NameRyde Group Ltd February 9, 2024 Page 2 FirstName LastName Zou Junming Terence Ryde Group Ltd February 9, 2024 Page 2 Please 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

Show Raw Text
United States securities and exchange commission logo
February 9, 2024
Zou Junming Terence
Chief Executive Officer
Ryde Group Ltd
Duo Tower, 3 Fraser Street, #08-21
Singapore 189352
Re:Ryde Group Ltd
Amendment No. 4 to Registration Statement on Form F-1
Filed February 6, 2024
File No. 333-274283
Dear Zou Junming Terence:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our February 5, 2024 letter.
Amendment No. 4 to Registration Statement on Form F-1 filed February 6, 2024
Capitalization, page 44
1.We read your response to prior comment 1. Please tell us how you determined the fair
value of the 2,086,561 Class A Ordinary Shares issued to consultants and 1,131,715 Class
A Ordinary Shares issued to your employees pursuant to the Scheme and the reasons for
any differences between the recent valuations of your common stock leading up to the
IPO and the estimated offering price. Also, please tell us your consideration of disclosing
how you accounted for the 2,086,561 Class A Ordinary Shares issued to consultants and
1,131,715 Class A Ordinary Shares issued to your employees in your Capitalization
Table.

 FirstName LastNameZou Junming Terence
 Comapany NameRyde Group Ltd
 February 9, 2024 Page 2
 FirstName LastName
Zou Junming Terence
Ryde Group Ltd
February 9, 2024
Page 2
            Please 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