SecProbe.io

United States securities and exchange commission logo
June 4, 2024
Wai Kee Kan
Chief Executive Officer
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 May 28, 2024
File No. 33-279752
Dear Wai Kee Kan:
            We have reviewed your 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.
Registration Statement on Form F-1 filed May 28, 2024
Explanatory Note, page i
1.Please update the disclosure in this section to reflect that this is a new registration
statement, and not a post-effective amendment to a registration statement on Form F-1.
General
2.Please file an updated, correct version of Exhibit 1.1.  We note that such exhibit does not
appear to include R.F. Lafferty.  We also note that the information in Schedule A, page 24
of Exhibit 1.1 is inconsistent with the disclosure on page 116 of the Form F-1.

 FirstName LastNameWai Kee Kan
 Comapany NameLinkers Industries Ltd
 June 4, 2024 Page 2
 FirstName LastName
Wai Kee Kan
Linkers Industries Ltd
June 4, 2024
Page 2
3.We note your disclosure on page Alt-14 that your selling securityholders may sell their
securities in one or more underwritten offerings on a firm commitment or best efforts
basis. Please confirm your understanding that the retention by a selling stockholder of an
underwriter would constitute a material change to your plan of distribution requiring a
post-effective amendment.  Refer to your undertaking provided pursuant to Item
512(a)(1)(iii) of Regulation S-K.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            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 Erin Donahue at 202-551-6063 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Ted Paraskevas