SEC Comment Letter 0000000000-24-000930 to SKK Holdings Ltd (SKK)
SKK Holdings Ltd
Date: Jan. 24, 2024 · CIK: 0001991261 · Accession: 0000000000-24-000930
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United States securities and exchange commission logo January 24, 2024 Koon Kiat Sze Chief Executive Officer SKK Holdings Limited 27 First Lok Yang Road Singapore 629735 Re:SKK Holdings Limited Amendment No. 5 to Draft Registration Statement on Form F-1 Submitted January 17, 2024 CIK No. 0001991261 Dear Koon Kiat Sze: We have reviewed your amended draft registration statement and have the following comments. 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 F-1 submitted January 17, 2024 Cover Page 1.Please disclose here and under Risk Factors on page 26, the number of shares the selling shareholders are offering for resale. Also clarify under Underwriting on page 116, that the resale shares are not locked up. General 2.Please file the consent of each director nominee as an exhibit to your registration statement. See Rule 438 of Regulation C under the Securities Act.
FirstName LastNameKoon Kiat Sze Comapany NameSKK Holdings Limited January 24, 2024 Page 2 FirstName LastName Koon Kiat Sze SKK Holdings Limited January 24, 2024 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
January 24, 2024
Koon Kiat Sze
Chief Executive Officer
SKK Holdings Limited
27 First Lok Yang Road
Singapore 629735
Re:SKK Holdings Limited
Amendment No. 5 to Draft Registration Statement on Form F-1
Submitted January 17, 2024
CIK No. 0001991261
Dear Koon Kiat Sze:
We have reviewed your amended draft registration statement and have the following
comments.
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 F-1 submitted January 17, 2024
Cover Page
1.Please disclose here and under Risk Factors on page 26, the number of shares the selling
shareholders are offering for resale. Also clarify under Underwriting on page 116, that the
resale shares are not locked up.
General
2.Please file the consent of each director nominee as an exhibit to your registration
statement. See Rule 438 of Regulation C under the Securities Act.
FirstName LastNameKoon Kiat Sze
Comapany NameSKK Holdings Limited
January 24, 2024 Page 2
FirstName LastName
Koon Kiat Sze
SKK Holdings Limited
January 24, 2024
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