SEC Comment Letter 0000000000-24-013856 to Luda Technology Group Ltd (LUD)
Luda Technology Group Ltd
Date: Dec. 17, 2024 · CIK: 0001984124 · Accession: 0000000000-24-013856
AI Filing Summary & Sentiment
File numbers found in text: 333-283680
Letter
December 17, 2024 Ma Biu Chief Executive Officer Luda Technology Group Ltd Unit H, 13/F, Kaiser Estate Phase 2 47-53 Man Yue Street Hung Hom, Kowloon Hong Kong Re:Luda Technology Group Ltd Registration Statement on Form F-1 Filed December 6, 2024 File No. 333-283680 Dear Ma Biu: We have reviewed your 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. Registration Statement on Form F-1 Certain Relationships and Related-Party Transactions, page 115 1.Please revise your disclosure in this section to provide information up to a more recent date as required by Item 7.B of Form 20-F. General 2.Please provide an opinion of counsel regarding the legality of the underwriters' warrants. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
December 17, 2024 Page 2 Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Charles Eastman at 202-551-3794 or Hugh West at 202-551-3872 if you have questions regarding comments on the financial statements and related matters. Please contact Evan Ewing at 202-551-5920 or Jay Ingram at 202-551-3397 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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December 17, 2024
Ma Biu
Chief Executive Officer
Luda Technology Group Ltd
Unit H, 13/F, Kaiser Estate Phase 2
47-53 Man Yue Street
Hung Hom, Kowloon
Hong Kong
Re:Luda Technology Group Ltd
Registration Statement on Form F-1
Filed December 6, 2024
File No. 333-283680
Dear Ma Biu:
We have reviewed your 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.
Registration Statement on Form F-1
Certain Relationships and Related-Party Transactions, page 115
1.Please revise your disclosure in this section to provide information up to a more recent
date as required by Item 7.B of Form 20-F.
General
2.Please provide an opinion of counsel regarding the legality of the underwriters'
warrants.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
December 17, 2024
Page 2
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Charles Eastman at 202-551-3794 or Hugh West at 202-551-3872 if
you have questions regarding comments on the financial statements and related
matters. Please contact Evan Ewing at 202-551-5920 or Jay Ingram at 202-551-3397 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing