SEC Comment Letter 0000000000-23-010417 to Ten-League International Holdings Ltd (TLIH)
Ten-League International Holdings Ltd
Date: Sept. 21, 2023 · CIK: 0001982012 · Accession: 0000000000-23-010417
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United States securities and exchange commission logo
September 21, 2023
Jison Lim
Director and Chairman
Ten-League International Holdings Ltd
16 Gul Drive
Singapore 629467
Re:Ten-League International Holdings Ltd
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted September 14, 2023
CIK No. 0001982012
Dear Jison Lim:
We have reviewed your amended draft registration statement and have the following
comment. In our comment, 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 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 comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 2 to Draft Registration Statement on Form F-1, Submitted September 14, 2023
Conventions That Apply to This Prospectus, page 8
1.We note the addition of disclosure on page 4 of SANY as the "Major Supplier."
Considering the materiality of Major Supplier to your business, please clearly identify
SANY as "Major Supplier" under "Conventions that Apply to This Prospectus." Please
also name SANY as the "Major Supplier" in other sections where you discuss your
dependence on SANY, such as the first risk factor on page 10, the related disclosure on
page 66, and the disclosure entitled "Major Suppliers" on page 81.
FirstName LastNameJison Lim
Comapany NameTen-League International Holdings Ltd
September 21, 2023 Page 2
FirstName LastName
Jison Lim
Ten-League International Holdings Ltd
September 21, 2023
Page 2
You may contact Nasreen Mohammed at 202-551-3773 or Lyn Shenk at 202-551-3380 if
you have questions regarding comments on the financial statements and related matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Erin Jaskot at 202-551-3442 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Louise L. Liu