SEC Comment Letter 0000000000-23-009763 to Silynxcom Ltd. (SYNX)
Silynxcom Ltd.
Date: Sept. 5, 2023 · CIK: 0001976443 · Accession: 0000000000-23-009763
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United States securities and exchange commission logo
September 5, 2023
Nir Klein
Chief Executive Officer
Silynxcom Ltd.
19 Yad Ha'Harutzim St.
Netanya, 4250519, Israel
Re:Silynxcom Ltd.
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted August 24, 2023
CIK No. 0001976443
Dear Nir Klein:
We have reviewed your amended draft 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 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 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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement of Form F-1 submitted August 24, 2023
Our Sales Process and Customers, page 50
1.We note your response to prior comment 9. If you elect to highlight names of your
customers, such as the Navy Seals, and the ones you identify are not included in the table
in this section, revise to make that clear.
Key Growth Strategies, page 53
2.Please file as an exhibit the contract mentioned in the second bullet point on page 54.
Major Milestones, page 54
FirstName LastNameNir Klein
Comapany NameSilynxcom Ltd.
September 5, 2023 Page 2
FirstName LastName
Nir Klein
Silynxcom Ltd.
September 5, 2023
Page 2
3.We note your response to prior comment 9. Please revise the disclosure on page 54 to
state how many active distributors that you currently have in your international distributor
network.
Employment and Service Agreements, page 62
4.We note your response to prior comment 10. Please revise to discuss the changes to the
terms of employment that will change after this offering. In this regard, we note that the
disclosure on page F-65 indicates that the terms of employment will change after this
offering.
Notes to the Audited Financial Statements, page F-8
5.We note your response to prior comment 12. Given the US Dollar is your reporting
currency, please revise your footnotes to provide information in US Dollars. For example,
we note the information included in Footnote 15 - Commitments and Pledges includes
substantial financial information in NIS without the equivalent US Dollar amount.
General
6.Please reconcile your revisions in response to prior comment 3 with your disclosure on
page F-9.
You may contact Mindy Hooker at (202) 551-3732 or Claire Erlanger at (202) 551-3301
if you have questions regarding comments on the financial statements and related
matters. Please contact Tom Jones at (202) 551-3602 or Geoff Kruczek at (202) 551-3641 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Oded Har-Even, Esq.