SEC Comment Letter 0000000000-23-013323 to SKK Holdings Ltd (SKK)
SKK Holdings Ltd
Date: Dec. 6, 2023 · CIK: 0001991261 · Accession: 0000000000-23-013323
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Letter
United States securities and exchange commission logo December 6, 2023 Koon Kiat Sze Chief Executive Officer SKK Holdings Limited 27 First Lok Yang Road Singapore 629735 Re:SKK Holdings Limited Amendment No. 3 to Draft Registration Statement on Form F-1 Submitted November 30, 2023 CIK No. 0001991261 Dear Koon Kiat Sze: We have reviewed your amended draft registration statement and have the following comment. 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. Form DRS/A F-1 Submitted November 30, 2023 Related Party Transactions, page 97 1.We note your response to prior comment 1; however, you have not included the disclosure required by Item 7.B of Form 20-F in this section of the prospectus. Therefore, we reissue the comment. In this section, add the transactions regarding the securities issued by the company to the related parties, as noted elsewhere in your filing, for example, on page 108. For each related party transaction, disclose the name of the related person and the basis on which the person is a related person, the amount involved and the material terms of the transaction. For example, disclose how your affiliates, including your officers, directors and major shareholders, are related to SKK Works Pte Ltd., quantify the amounts involved with the SKK Works Pte Ltd transactions, and describe the material terms of these transactions.
FirstName LastNameKoon Kiat Sze Comapany NameSKK Holdings Limited December 6, 2023 Page 2 FirstName LastName Koon Kiat Sze SKK Holdings Limited December 6, 2023 Page 2 Please contact Babette Cooper at 202-551-3396 or Isaac Esquivel at 202-551-3395 if you have questions regarding comments on the financial statements and related matters. Please contact Pearlyne Paulemon at 202-551-8714 or Brigitte Lippmann at 202-551-3713 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: David L. Ficksman
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United States securities and exchange commission logo
December 6, 2023
Koon Kiat Sze
Chief Executive Officer
SKK Holdings Limited
27 First Lok Yang Road
Singapore 629735
Re:SKK Holdings Limited
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted November 30, 2023
CIK No. 0001991261
Dear Koon Kiat Sze:
We have reviewed your amended draft registration statement and have the following
comment.
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.
Form DRS/A F-1 Submitted November 30, 2023
Related Party Transactions, page 97
1.We note your response to prior comment 1; however, you have not included the disclosure
required by Item 7.B of Form 20-F in this section of the prospectus. Therefore, we reissue
the comment. In this section, add the transactions regarding the securities issued by the
company to the related parties, as noted elsewhere in your filing, for example, on page
108. For each related party transaction, disclose the name of the related person and the
basis on which the person is a related person, the amount involved and the material terms
of the transaction. For example, disclose how your affiliates, including your officers,
directors and major shareholders, are related to SKK Works Pte Ltd., quantify the
amounts involved with the SKK Works Pte Ltd transactions, and describe the material
terms of these transactions.
FirstName LastNameKoon Kiat Sze
Comapany NameSKK Holdings Limited
December 6, 2023 Page 2
FirstName LastName
Koon Kiat Sze
SKK Holdings Limited
December 6, 2023
Page 2
Please contact Babette Cooper at 202-551-3396 or Isaac Esquivel at 202-551-3395 if you
have questions regarding comments on the financial statements and related matters. Please
contact Pearlyne Paulemon at 202-551-8714 or Brigitte Lippmann at 202-551-3713 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: David L. Ficksman