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Correspondence 0001213900-24-081748 from Luda Technology Group Ltd (LUD)

Luda Technology Group Ltd
Date: Sept. 25, 2024 · CIK: 0001984124 · Accession: 0001213900-24-081748

AI Filing Summary & Sentiment

File numbers found in text: 333-277647

Referenced dates: September 25, 2024

Date
September 25, 2024
Author
/s/ Lawrence S. Venick
Form
CORRESP
Company
Luda Technology Group Ltd

Letter

Division of Corporation Finance Office of Manufacturing Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549

Re: Luda Technology Group Limited

Dear SEC Officers:

On behalf of Luda Technology Group Limited (the “Company”), we have set forth below responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission contained in its letter dated September 25, 2024 with respect to the Registration Statement on Form F-1, File No. 333-277647 (“F-1”), submitted on September 20, 2024 by the Company. For your convenience, the text of the Staff’s comments is set forth below in bold, followed in each case by the Company’s responses.

Registration Statement on Form F-1

Exhibits

1. We note your disclosure that you are registering 143,750 underwriters’ warrants. Please provide an opinion of counsel regarding the legality of the warrants.

Response: In response to the Staff’s comment, the Company has filed Exhibit 5.2 in the Registration Statement.

Should you have any questions relating to the foregoing or wish to discuss any aspect of the Company’s filing, please contact me at +852.5600.0188.

Very truly yours,
/s/ Lawrence S. Venick

Show Raw Text
CORRESP
1
filename1.htm

September 25, 2024

    Re:
    Luda Technology Group Limited

    Amendment No. 4 to

    Registration Statement on Form F-1

    Submitted September 20, 2024

    File No. 333-277647

Mr. Alex King and Mr. Evan Ewing

Division of Corporation Finance

Office of Manufacturing

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Dear SEC Officers:

On behalf of Luda Technology
Group Limited (the “Company”), we have set forth below responses to the comments of the staff (the “Staff”) of
the Securities and Exchange Commission contained in its letter dated September 25, 2024 with respect to the Registration Statement on
Form F-1, File No. 333-277647 (“F-1”), submitted on September 20, 2024 by the Company. For your convenience, the text of the
Staff’s comments is set forth below in bold, followed in each case by the Company’s responses.

Registration Statement on Form F-1

Exhibits

    1.
    We note your disclosure that you are registering 143,750 underwriters’ warrants. Please provide an opinion of counsel regarding the legality of the warrants.

Response: In response to the Staff’s
comment, the Company has filed Exhibit 5.2 in the Registration Statement.

Should you have any questions relating to the
foregoing or wish to discuss any aspect of the Company’s filing, please contact me at +852.5600.0188.

    Very truly yours,

    /s/ Lawrence S. Venick

    Lawrence S. Venick