SecProbe.io

October 10, 2024
Foo Chee Weng Desmond
Director, Chairman and Chief Executive Officer
Enigmatic Limited
c/o 3 Shenton Way,
Shenton House, #23-01
Singapore 068805
Re:Enigmatic Limited
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted September 17, 2024
CIK No. 0001982961
Dear Foo Chee Weng Desmond:
            We have reviewed your amended draft registration statement and have the following
comment(s).
            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, any references to prior comments are to comments in
our July 19, 2024 letter.
Amendment No. 3 to Draft Registration Statement on Form F-1 submitted September 17,
2024
Consolidated Financial Statements
Note 4. Cash and cash equivalents, page F-16
We read your response to prior comment 6. Excerpts from Tether's terms of service
state:
•The composition of the Reserves used to back Tether Tokens is within the sole
control and at the sole and absolute discretion of Tether.
In order to cause Tether Tokens to be issued or redeemed directly by Tether, you •1.

October 10, 2024
Page 2
must be a verified customer of Tether. No exceptions will be made to this
provision.
•Tether reserves the right to delay the redemption or withdrawal of Tether Tokens
if such delay is necessitated by the illiquidity or unavailability or loss of any
Reserves held by Tether to back the Tether Tokens, and Tether reserves the right
to redeem Tether Tokens by in-kind redemptions of securities and other assets
held in the Reserves.
You do not appear to be a verified customer of Tether. In addition, Tether has non-
financial assets in its Reserves, such as precious metals, bitcoins and other
investments that a customer could receive upon an in-kind redemption. Accordingly,
it appears your USDT represents a non-financial asset. Please restate your financial
statements and revise your disclosures surrounding USDT throughout the filing
accordingly. Refer to ASC 350-30. Please also make arrangements with your auditors
for them to revise their report to include an explanatory paragraph (immediately
following the opinion paragraph), stating the previously issued financial statements
have been restated for the correction of a misstatement and referencing the Note to the
financial statements, where the restatement is described. Refer to paragraphs .09 and
.16 of PCAOB AS 2820. Finally, revise your financial statements to label them as
restated and provide the footnote disclosures required by ASC 250-10-50-7 through
50-11. In the restatement footnote, clearly disclose (a) the nature of the error and (b)
the effect of the error correction by presenting the as originally reported amount, the
error correction amount and the as restated amount for each financial statement line
item that changed.
            Please contact Suying Li at 202-551-3335 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters. Please
contact Brian Fetterolf at 202-551-6613 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Mathew Lewis