SEC Comment Letter 0000000000-23-010946 to ORANGEKLOUD TECHNOLOGY INC. (ORKT) (CIK 0001979407) (ORKT)
ORANGEKLOUD TECHNOLOGY INC. (ORKT) (CIK 0001979407)
Date: Oct. 4, 2023 · CIK: 0001979407 · Accession: 0000000000-23-010946
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo October 4, 2023 Kian Hwa Goh Chief Executive Officer Orangekloud Technology Inc. 1 Yishun Industrial Street 1 #04-27/28&34 Aposh Building Bizhub Singapore, 768160 Re:Orangekloud Technology Inc. Amendment No. 3 to Draft Registration Statement on Form F-1 Submitted September 28, 2023 CIK No. 0001979407 Dear Kian Hwa Goh: We have reviewed your amended draft registration statement and have the following comments. 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 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 the information you provide in response to this letter and your amended draft registration statement or filed registration statement, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 26, 2023 letter. Amendment No. 3 to Draft Registration Statement on Form F-1 Management's Discussion and Analysis of Financial Condition and Results of Operations Other Metrics, page 41 1.We note the revisions made in response to prior comment 1. Please explain further what you mean by "application software on premise at one-time off paying on the software contributed from third party products." In addition, we note your current revenue recognition policy on F-13 only includes third-party licenses. Please revise to discuss how you recognize revenue from these non-recurring third-party products.
FirstName LastNameKian Hwa Goh Comapany NameOrangekloud Technology Inc. October 4, 2023 Page 2 FirstName LastName Kian Hwa Goh Orangekloud Technology Inc. October 4, 2023 Page 2 General 2.We note your response to prior comment 2. Please expand your disclosure to include a discussion of the effect the Reorganization will have on the company’s shareholders. Please contact Chen Chen at 202-551-7351 or Christine Dietz at 202-551-3408 if you have questions regarding comments on the financial statements and related matters. Please contact Alexandra Barone at 202-551-8816 or Matthew Derby at 202-551-3334 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Lawrence Venick
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United States securities and exchange commission logo
October 4, 2023
Kian Hwa Goh
Chief Executive Officer
Orangekloud Technology Inc.
1 Yishun Industrial Street 1
#04-27/28&34 Aposh Building Bizhub
Singapore, 768160
Re:Orangekloud Technology Inc.
Amendment No. 3 to
Draft Registration Statement on Form F-1
Submitted September 28, 2023
CIK No. 0001979407
Dear Kian Hwa Goh:
We have reviewed your amended draft registration statement and have the following
comments.
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 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 the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
September 26, 2023 letter.
Amendment No. 3 to Draft Registration Statement on Form F-1
Management's Discussion and Analysis of Financial Condition and Results of Operations
Other Metrics, page 41
1.We note the revisions made in response to prior comment 1. Please explain further what
you mean by "application software on premise at one-time off paying on the software
contributed from third party products." In addition, we note your current revenue
recognition policy on F-13 only includes third-party licenses. Please revise to discuss how
you recognize revenue from these non-recurring third-party products.
FirstName LastNameKian Hwa Goh
Comapany NameOrangekloud Technology Inc.
October 4, 2023 Page 2
FirstName LastName
Kian Hwa Goh
Orangekloud Technology Inc.
October 4, 2023
Page 2
General
2.We note your response to prior comment 2. Please expand your disclosure to include a
discussion of the effect the Reorganization will have on the company’s shareholders.
Please contact Chen Chen at 202-551-7351 or Christine Dietz at 202-551-3408 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alexandra Barone at 202-551-8816 or Matthew Derby at 202-551-3334 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Lawrence Venick