Correspondence 0001493152-24-004124 from SKK Holdings Ltd (SKK)
SKK Holdings Ltd
Date: Jan. 29, 2024 · CIK: 0001991261 · Accession: 0001493152-24-004124
AI Filing Summary & Sentiment
Reasoning
Referenced dates: January 24, 2024
Letter
SKK Holdings Limited
First Lok Yang
Singapore
January 29, 2024
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549
Attention: Babette Cooper
Re: SKK Holdings Limited
Amendment No. 6 to Draft Registration Statement on Form F-1
Submitted January 17, 2024
CIK No. 0001991261
Ladies and Gentlemen:
By letter dated January 24, 2024, the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) provided SKK Holdings Limited (the “Company”) with comments on the Company’s Amendment No. 5 to Draft Registration Statement on Form F-1, described above. This letter contains the Company’s responses to the Staff’s comments. Concurrently herewith, the Company is filing Amendment No. 6 to Draft Registration Statement on Form F-1 (the “Registration Statement Amendment”).
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.
RESPONSE: We note the Staff’s comment and have revised the disclosure on cover page and page 26 of the Registration Statement Amendment.
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.
RESPONSE: We note the Staff’s comment and have filed the consent on exhibit 99.1, 99.2 and 99.3 of the Registration Statement Amendment.
Sincerely,
SKK
Holdings Limited
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CORRESP
1
filename1.htm
SKK
Holdings Limited
27
First Lok Yang
Singapore
629735
January
29, 2024
VIA
EDGAR
Securities
and Exchange Commission
Division
of Corporation Finance
Washington,
D.C. 20549
Attention:
Babette Cooper
Re:
SKK
Holdings Limited
Amendment
No. 6 to Draft Registration Statement on Form F-1
Submitted
January 17, 2024
CIK
No. 0001991261
Ladies
and Gentlemen:
By
letter dated January 24, 2024, the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
provided SKK Holdings Limited (the “Company”) with comments on the Company’s Amendment No. 5 to Draft Registration
Statement on Form F-1, described above. This letter contains the Company’s responses to the Staff’s comments. Concurrently
herewith, the Company is filing Amendment No. 6 to Draft Registration Statement on Form F-1 (the “Registration Statement Amendment”).
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.
RESPONSE:
We note the Staff’s comment and have revised the disclosure on cover page and page 26 of the Registration Statement Amendment.
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.
RESPONSE:
We note the Staff’s comment and have filed the consent on exhibit 99.1, 99.2 and 99.3 of the Registration Statement Amendment.
Sincerely,
SKK
Holdings Limited
/s/
Koon Kiat Sze
Koon
Kiat Sze
Chief
Executive Officer
cc:
David
L. Ficksman
R.
Joilene Wood