SEC Comment Letter 0000000000-23-013711 to Linkers Industries Ltd (LNKS) (CIK 0001972074) (LNKS)
Linkers Industries Ltd (LNKS) (CIK 0001972074)
Date: Dec. 15, 2023 · CIK: 0001972074 · Accession: 0000000000-23-013711
AI Filing Summary & Sentiment
File numbers found in text: 333-275953
Letter
United States securities and exchange commission logo December 15, 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 Registration Statement on Form F-1 Filed December 8, 2023 File No. 333-275953 Dear Man Tak Lau: We have reviewed your amended registration statement and have the following comments. 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 November 7, 2023 letter. Registration Statement on Form F-1 filed December 8, 2023 Exhibits 1.Refer to Exhibit 5.1. The opinion regarding the legality of the issuance must address each transaction you are attempting to register. It appears the opinion you filed does not address the resale transaction included in your fee table, given that the opinion does not opine that the shares to be resold are currently duly authorized, validly issued and non- assessable. Please file a revised opinion. 2.Refer to Exhibit 23.4. Please ask counsel to provide its consent to each reference to its name. Currently, this exhibit does not include the reference on page 29. 3.Refer to Exhibit 8.2 and 23.3. Please have counsel provide an exhibit that includes its clear consent to each reference to its name in the registration statement and to the filing of this opinion as an exhibit. Also, though this exhibit purports to be a tax opinion, it does
FirstName LastNameMan Tak Lau Comapany NameLinkers Industries Ltd December 15, 2023 Page 2 FirstName LastName Man Tak Lau Linkers Industries Ltd December 15, 2023 Page 2 not state that the statements in the disclosure beginning on page 106 are counsel's opinion. Please file a revised opinion. General 4.Please revise to identify the natural person(s) who have or share voting and/or dispositive powers with respect to the shares held by the entities in the table on page Alt-13. 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
December 15, 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
Registration Statement on Form F-1
Filed December 8, 2023
File No. 333-275953
Dear Man Tak Lau:
We have reviewed your amended registration statement and have the following
comments.
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 November 7, 2023 letter.
Registration Statement on Form F-1 filed December 8, 2023
Exhibits
1.Refer to Exhibit 5.1. The opinion regarding the legality of the issuance must address each
transaction you are attempting to register. It appears the opinion you filed does not
address the resale transaction included in your fee table, given that the opinion does not
opine that the shares to be resold are currently duly authorized, validly issued and non-
assessable. Please file a revised opinion.
2.Refer to Exhibit 23.4. Please ask counsel to provide its consent to each reference to its
name. Currently, this exhibit does not include the reference on page 29.
3.Refer to Exhibit 8.2 and 23.3. Please have counsel provide an exhibit that includes its
clear consent to each reference to its name in the registration statement and to the filing of
this opinion as an exhibit. Also, though this exhibit purports to be a tax opinion, it does
FirstName LastNameMan Tak Lau
Comapany NameLinkers Industries Ltd
December 15, 2023 Page 2
FirstName LastName
Man Tak Lau
Linkers Industries Ltd
December 15, 2023
Page 2
not state that the statements in the disclosure beginning on page 106 are counsel's
opinion. Please file a revised opinion.
General
4.Please revise to identify the natural person(s) who have or share voting and/or dispositive
powers with respect to the shares held by the entities in the table on page Alt-13.
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