SEC Comment Letter 0000000000-23-012166 to Linkers Industries Ltd (LNKS) (CIK 0001972074) (LNKS)
Linkers Industries Ltd (LNKS) (CIK 0001972074)
Date: Nov. 7, 2023 · CIK: 0001972074 · Accession: 0000000000-23-012166
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo November 7, 2023 Man Tak Lau Director and Chairman of the Board of Directors Linkers Industries Ltd Lot A99, Jalan 2A-3, A101 & A102, Jalan 2A, Kawasan Perusahaan MIEL Sungai Lalang, 08000 Sungai Petani, Kedah Darul Aman, Malaysia Re:Linkers Industries Ltd Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted October 26, 2023 CIK 1972074 Dear Man Tak Lau: We have reviewed your amended draft registration statement and have the following comments. 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 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 the information you provide in response to this letter and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 1 to Form 1 submitted October 26, 2023 General 1.We note your response to prior comment 2. Please tell us how, going forward, the company would determine whether more than 50 percent of its outstanding voting securities are owned of record by U.S. residents for purposes of satisfying the foreign private issuer definition. See Securities Act Rule 405 and Exchange Act Rule 3b-4; Securities Act Rules Compliance and Disclosure Interpretation 203.17. Use of Proceeds, page 39 2.We note your response to prior comment 4. Please additionally revise your disclosure, here and throughout the registration statement, to include where you are in the acquisition process, such as whether any understandings or agreements exist between you and any target company or joint venture partner.
FirstName LastNameMan Tak Lau Comapany NameLinkers Industries Ltd November 7, 2023 Page 2 FirstName LastName Man Tak Lau Linkers Industries Ltd November 7, 2023 Page 2 Diversified Customer Base, page 60 3.We note your response to prior comment 6. Please specifically identify the "key customers who are renowned global brand name manufacturers and OEMs" described in this section. Board of Directors, page 84 4.We note your response to prior comment 8. Please amend your disclosure prior to effectiveness, with the identities of all independent directors. Please contact Andi Carpenter at 202-551-3645 or Andrew Blume at 202-551-3254 if you have questions regarding comments on the financial statements and related matters. Please contact Gregory Herbers at 202-551-8028 or Geoffrey Kruczek at 202-551-3641 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Lawrence Venick
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United States securities and exchange commission logo
November 7, 2023
Man Tak Lau
Director and Chairman of the Board of Directors
Linkers Industries Ltd
Lot A99, Jalan 2A-3, A101 & A102, Jalan 2A, Kawasan Perusahaan MIEL
Sungai Lalang, 08000 Sungai Petani, Kedah Darul Aman, Malaysia
Re:Linkers Industries Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted October 26, 2023
CIK 1972074
Dear Man Tak Lau:
We have reviewed your amended draft registration statement and have the following
comments.
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 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 the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Amendment No. 1 to Form 1 submitted October 26, 2023
General
1.We note your response to prior comment 2. Please tell us how, going forward, the
company would determine whether more than 50 percent of its outstanding voting
securities are owned of record by U.S. residents for purposes of satisfying the foreign
private issuer definition. See Securities Act Rule 405 and Exchange Act Rule 3b-4;
Securities Act Rules Compliance and Disclosure Interpretation 203.17.
Use of Proceeds, page 39
2.We note your response to prior comment 4. Please additionally revise your disclosure,
here and throughout the registration statement, to include where you are in the acquisition
process, such as whether any understandings or agreements exist between you and any
target company or joint venture partner.
FirstName LastNameMan Tak Lau
Comapany NameLinkers Industries Ltd
November 7, 2023 Page 2
FirstName LastName
Man Tak Lau
Linkers Industries Ltd
November 7, 2023
Page 2
Diversified Customer Base, page 60
3.We note your response to prior comment 6. Please specifically identify the "key customers
who are renowned global brand name manufacturers and OEMs" described in this section.
Board of Directors, page 84
4.We note your response to prior comment 8. Please amend your disclosure prior to
effectiveness, with the identities of all independent directors.
Please contact Andi Carpenter at 202-551-3645 or Andrew Blume at 202-551-3254 if you
have questions regarding comments on the financial statements and related matters. Please
contact Gregory Herbers at 202-551-8028 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Lawrence Venick