Correspondence 0001213900-24-111744 from Luda Technology Group Ltd (LUD)
Luda Technology Group Ltd
Date: Dec. 23, 2024 · CIK: 0001984124 · Accession: 0001213900-24-111744
AI Filing Summary & Sentiment
File numbers found in text: 333-283680
Referenced dates: December 17, 2024
Letter
Via Edgar Transmission Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services Luda Technology Group Ltd Registration Statement on Form F-1 Filed December 6, 2024 File No. 333-283680
Re:
Dear Mr. Ewing / Mr. Ingram:
As counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated December 17, 2024 from the Securities and Exchange Commission (the “Commission”) in which the staff of the Commission (the “Staff”) commented on the above-referenced Draft Registration Statement on Form F-1 (the “Form F-1”).
For the Staff’s convenience, the Staff’s comment has been stated below in its entirety, with the Company’s response set out immediately underneath such comment.
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.
Response: We respectfully advise the Staff that we have updated the disclosure on page 115 to disclose the above.
General
2. Please provide an opinion of counsel regarding the legality of the underwriters' warrants.
Response: We respectfully advise the Staff that we have included Loeb & Loeb LLP’s opinion on the legality of the underwriters’ warrants.
* * *
Please contact the undersigned at (852) 3923-1188 if you have any questions with respect to the responses contained in this letter.
Sincerely,
/s/ Lawrence S. Venick
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December 23, 2024
Via Edgar Transmission
Mr. Evan Ewing / Jay Ingram
Securities and Exchange Commission
Division of Corporation Finance
Office of Trade & Services
Washington, D.C. 20549
Re:
Luda Technology Group Ltd
Registration Statement on Form F-1
Filed December 6, 2024
File No. 333-283680
Dear Mr. Ewing / Mr. Ingram:
As counsel for the Company
and on its behalf, this letter is being submitted in response to the letter dated December 17, 2024 from the Securities and Exchange Commission
(the “Commission”) in which the staff of the Commission (the “Staff”) commented on the above-referenced
Draft Registration Statement on Form F-1 (the “Form F-1”).
For the Staff’s convenience,
the Staff’s comment has been stated below in its entirety, with the Company’s response set out immediately underneath such
comment.
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.
Response: We respectfully advise
the Staff that we have updated the disclosure on page 115 to disclose the above.
General
2. Please provide an opinion of counsel regarding the legality of the underwriters' warrants.
Response: We respectfully advise
the Staff that we have included Loeb & Loeb LLP’s opinion on the legality of the underwriters’ warrants.
* * *
Please contact the undersigned
at (852) 3923-1188 if you have any questions with respect to the responses contained in this letter.
Sincerely,
/s/ Lawrence S. Venick
Lawrence S. Venick
Direct Dial: +852.3923.1188
Email: lvenick@loeb.com