CORRESP Filing
Globavend Holdings Ltd
Date: May 22, 2025 · CIK: 0001978527 · Accession: 0001213900-25-046968
AI Filing Summary & Sentiment
Referenced dates: May 6, 2025
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CORRESP 1 filename1.htm May 22, 2025 Via EDGAR Division of Corporate Finance Officer of Energy & Transportation U.S. Securities and Exchange Commission 100 F Street NE Washington, D.C., 20549 Re: Globavend Holdings Limited Draft Registration on Form F-1 Response to the Staff's Comments Dated May 6, 2025 CIK No.0001978527 Dear Ms. Barberena-Meissner and Mr. Morris: We, Globavend Holdings Limited (the " Company "), a foreign private issuer incorporated in the Cayman Islands, submit to the staff (the " Staff ") of the U.S. Securities and Exchange Commission (the " Commission ") this letter setting forth the Company's responses to the comments contained in the Staff's letter dated as of May 6, 2025 on the Company's draft registration statement on Form F-1 confidentially submitted on April 15, 2025. Concurrently with the submission of this letter, the Company is filing its registration statement on Form F-1 (the " Registration Statement ") and certain exhibits via EDGAR to the Commission. The Staff's comments from its letter dated May 6, 2025 are repeated below in bold and followed by the Company's responses. We have included page numbers to refer to the location in the Registration Statement where the language addressing the comments appears. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Registration Statement. Draft Registration Statement on Form F-1 submitted April 15, 2025 Risk Factors We have received a deficiency letter from Nasdaq relating to our non-compliance with Nasdaq's continued listing requirements, page 15 1. Please revise your risk factor disclosure here and elsewhere as appropriate to disclose that this offering could cause the price of your Ordinary Shares to fall below the minimum bid price, which could result in your Ordinary Shares being delisted from Nasdaq. In response to the Staff's comment, the Company has included the referenced disclosure on pages 14 of the Registration Statement. If you have any questions or further comments regarding the Registration Statement, please contact me via email at project@globavend.com. Very truly yours, /s/ Wai Yiu Yau Name: Wai Yiu Yau Title: Director and CEO c.c.: Aaron M. Schleicher, Esq.