Correspondence 0001493152-23-029827 from SRIVARU Holding Ltd (SVMH, SVMHW) (CIK 0001973368) (SVUHF)
SRIVARU Holding Ltd (SVMH, SVMHW) (CIK 0001973368)
Date: Aug. 22, 2023 · CIK: 0001973368 · Accession: 0001493152-23-029827
AI Filing Summary & Sentiment
File numbers found in text: 333-272717
Referenced dates: August 15, 2023
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CORRESP
1
filename1.htm
Norton Rose Fulbright
US LLP
1301 Sixth Avenue
New York, NY 10019 United
States
Direct line +1 (212) 318-3168
Rajiv.Khanna@nortonrosefulbright.com
nortonrosefulbright.com
August
22, 2023
VIA
EDGAR
Securities
and Exchange Commission
Division
of Corporation Finance
100
F Street, N.E.
Washington,
D.C. 20549
Division
of Corporation Finance
Office
of Manufacturing
Attention:
Eranga
Dias
Erin
Purnell
Re:
SRIVARU
Holding Ltd
Amendment
No. 2 to Registration Statement on Form F-4
Filed
August 7, 2023
File
No. 333-272717
Dear
Mr. Dias and Ms. Purnell:
On
behalf of SRIVARU Holding Ltd (“SVH”, the “Registrant” or the “Company”), we are submitting via EDGAR
for review by the Securities and Exchange Commission (the “Commission”) this response letter and the accompanying Amendment
No. 3 (the “Amendment No. 3”) to the Registrant’s above-referenced Amendment No. 2 filed August 7, 2023 (“Amendment
No. 2”), to its Registration Statement on Form F-4 (the “Registration Statement”). This letter and Amendment No. 3
reflect the Registrant’s respectful acknowledgement and response to the comments received from the staff of the Commission (the
“Staff”) contained in the Staff’s letter dated August 15, 2023 (the “Comment Letter”), regarding Amendment
No. 2, and certain other updated information. Because some of the items in the Comment Letter pertain to information regarding Mobiv
Acquisition Corp (“MOBV”), we have included MOBV’s response in-line below. For your convenience, the Registrant is
providing to the Staff a supplemental typeset copy of the Registration Statement marked to indicate the changes from Amendment No. 2.
The
Staff’s comments as reflected in the Comment Letter are reproduced in italics in this letter, and the corresponding responses of
the Registrant are shown below each comment.
Amendment
No. 2 to Registration Statement on Form F-4
Notes
to Unaudited Pro Forma Condensed Combined Financial Statements
Note
4 - Adjustments to Unaudited Pro Forma Condensed Combined Balance Sheet as of March
31,
2023, page 196
1.
Please
amend your filing to include descriptions of all pro forma adjustments included on the pro forma balance sheet. In this regard, we
note that adjustments K through N do not appear to be explained in Note 4 to the Pro Forma Financial Statements.
Response:
Amendment No. 3 includes descriptions of all pro forma adjustments included on the pro forma balance sheet.
MOIV
Acquisition Corp. Financial Statements, page F-1
2.
Please
update the MOBIV Acquisition Corp financial statements for the quarter ended June 30, 2023.
Response:
MOBV has inserted its financial statements for the quarter ended June 30, 2023, in Amendment No. 3.
General
3.
Please
revise to include a currently dated consent of your independent registered public accounting firm.
Response:
MOBV’s independent registered public accounting firm has provided a currently dated consent, which is attached as Exhibit 23.2
to Amendment No. 3.
4.
Please
file a pre-effective amendment to the proxy statement/prospectus that includes all exhibits and all non-430A information, including
the amount of securities to be offered on the cover page, the identity and contact info of the proxy solicitor, and the per share
information on page 205. To the extent that you have set the record date, please fill that in and include all related information
as well.
Response:
Amendment No. 3 includes all exhibits not previously filed and all non-430A information.
Very
Truly Yours,
By:
/s/
Rajiv Khanna
Rajiv
Khanna
cc:
Mohanraj
Ramasamy (SRIVARU Holding Ltd)
Lee
McIntyre (Norton Rose Fulbright US LLP)