SEC Comment Letter 0000000000-23-009450 to ARM HOLDINGS PLC /UK (ARM) (CIK 0001973239) (ARM)
ARM HOLDINGS PLC /UK (ARM) (CIK 0001973239)
Date: Aug. 28, 2023 · CIK: 0001973239 · Accession: 0000000000-23-009450
AI Filing Summary & Sentiment
File numbers found in text: 333-274120
Letter
United States securities and exchange commission logo August 28, 2023 Spencer Collins Chief Legal Officer Arm Holdings Limited 110 Fulbourn Road Cambridge CB1 9NJ United Kingdom Re:Arm Holdings Limited Registration Statement on Form F-1 Filed August 21, 2023 File No. 333-274120 Dear Spencer Collins: We have reviewed your amended 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 amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Form F-1 filed August 21, 2023 Capitalization, page 84 1.We note that the table presents your cash and cash equivalents and capitalization as of June 30, 2023. Please remove the cash and cash equivalents from your total capitalization amounts, as cash and cash equivalents are not part of your capitalization, and include bold or double underlines and additional spacing following the cash and cash equivalents amounts to highlight to investors that the two amounts are separate.
FirstName LastNameSpencer Collins Comapany NameArm Holdings Limited August 28, 2023 Page 2 FirstName LastName Spencer Collins Arm Holdings Limited August 28, 2023 Page 2 You may contact Heather Clark at 202-551-3624 or Martin James at 202-551-3671 if you have questions regarding comments on the financial statements and related matters. Please contact Jenny O'Shanick at 202-551-8005 or Erin Purnell at 202-551-3454 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Justin Salon
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United States securities and exchange commission logo
August 28, 2023
Spencer Collins
Chief Legal Officer
Arm Holdings Limited
110 Fulbourn Road
Cambridge CB1 9NJ
United Kingdom
Re:Arm Holdings Limited
Registration Statement on Form F-1
Filed August 21, 2023
File No. 333-274120
Dear Spencer Collins:
We have reviewed your amended 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 amending your registration statement and providing the
requested information. 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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form F-1 filed August 21, 2023
Capitalization, page 84
1.We note that the table presents your cash and cash equivalents and capitalization as of
June 30, 2023. Please remove the cash and cash equivalents from your total capitalization
amounts, as cash and cash equivalents are not part of your capitalization, and include bold
or double underlines and additional spacing following the cash and cash
equivalents amounts to highlight to investors that the two amounts are separate.
FirstName LastNameSpencer Collins
Comapany NameArm Holdings Limited
August 28, 2023 Page 2
FirstName LastName
Spencer Collins
Arm Holdings Limited
August 28, 2023
Page 2
You may contact Heather Clark at 202-551-3624 or Martin James at 202-551-3671 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jenny O'Shanick at 202-551-8005 or Erin Purnell at 202-551-3454 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Justin Salon