SEC Comment Letter 0000000000-24-006911 to Ten-League International Holdings Ltd (TLIH)
Ten-League International Holdings Ltd
Date: June 17, 2024 · CIK: 0001982012 · Accession: 0000000000-24-006911
AI Filing Summary & Sentiment
File numbers found in text: 333-275240
Letter
United States securities and exchange commission logo June 17, 2024 Jison Lim Director and Chairman Ten-League International Holdings Ltd 7 Tuas Avenue 2 Singapore 639447 Re:Ten-League International Holdings Ltd Amendment No. 5 to Registration Statement on Form F-1 Filed June 4, 2024 File No. 333-275240 Dear Jison Lim: We have reviewed your amended registration statement and have the following comment(s). Please respond to this letter by amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our March 4, 2024 letter. Amendment No. 5 to Registration Statement on Form F-1, Filed June 4, 2024 Capitalization, page 36 1.The column heading shows the capitalization table is presented in US dollars. However, the “Actual” balances appear to be in Singapore $ as of December 31, 2023. Please revise or advise. 2.We note the “As adjusted” column in your capitalization table. Please explain how you computed “As adjusted” additional paid-in capital balance of $10,096,000 considering $7 million offering proceeds after deducting expenses on page 35. Please revise or advise. Liquidity and Capital Resources, page 50 3.We note gross accounts receivables increased approximately S$8.3 million or 49% but the allowance for doubtful accounts decreased S$0.6 million or 14% for the year ended
FirstName LastNameJison Lim Comapany NameTen-League International Holdings Ltd June 17, 2024 Page 2 FirstName LastName Jison Lim Ten-League International Holdings Ltd June 17, 2024 Page 2 December 31, 2023. We also note the aging of accounts receivables specifically over 120 days increased S$2.5 million or 54%. Given the significance of accounts receivables over 120 days, please consider expanding your schedule (such as past due 180, 360 and over 360 days, as applicable). Also in your working capital discussion, please discuss the underlying reasons for the increase in the days accounts receivables remain outstanding. Principal and Selling Shareholders, page 112 4.Please include an address for each person listed. We note that you previously included an address at 16 Gul Drive, but this section is now blank. Please 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
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United States securities and exchange commission logo
June 17, 2024
Jison Lim
Director and Chairman
Ten-League International Holdings Ltd
7 Tuas Avenue 2
Singapore 639447
Re:Ten-League International Holdings Ltd
Amendment No. 5 to Registration Statement on Form F-1
Filed June 4, 2024
File No. 333-275240
Dear Jison Lim:
We have reviewed your amended registration statement and have the following
comment(s).
Please respond to this letter by amending your registration statement and providing the
requested information. 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 any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our March 4, 2024 letter.
Amendment No. 5 to Registration Statement on Form F-1, Filed June 4, 2024
Capitalization, page 36
1.The column heading shows the capitalization table is presented in US dollars. However,
the “Actual” balances appear to be in Singapore $ as of December 31, 2023. Please revise
or advise.
2.We note the “As adjusted” column in your capitalization table. Please explain how you
computed “As adjusted” additional paid-in capital balance of $10,096,000 considering $7
million offering proceeds after deducting expenses on page 35. Please revise or advise.
Liquidity and Capital Resources, page 50
3.We note gross accounts receivables increased approximately S$8.3 million or 49% but the
allowance for doubtful accounts decreased S$0.6 million or 14% for the year ended
FirstName LastNameJison Lim
Comapany NameTen-League International Holdings Ltd
June 17, 2024 Page 2
FirstName LastName
Jison Lim
Ten-League International Holdings Ltd
June 17, 2024
Page 2
December 31, 2023. We also note the aging of accounts receivables specifically over 120
days increased S$2.5 million or 54%. Given the significance of accounts receivables
over 120 days, please consider expanding your schedule (such as past due 180, 360 and
over 360 days, as applicable). Also in your working capital discussion, please discuss the
underlying reasons for the increase in the days accounts receivables remain outstanding.
Principal and Selling Shareholders, page 112
4.Please include an address for each person listed. We note that you previously included an
address at 16 Gul Drive, but this section is now blank.
Please 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