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Correspondence 0001493152-24-011155 from SKK Holdings Ltd (SKK)

SKK Holdings Ltd
Date: March 25, 2024 · CIK: 0001991261 · Accession: 0001493152-24-011155

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File numbers found in text: 333-276744

Date
March 25, 2024
Author
Managing Director
Form
CORRESP
Company
SKK Holdings Ltd

Letter

March 25, 2024

VIA EDGAR TRANSMISSION

Division of Corporate Finance

United States Securities and Exchange Commission

F Street, N.E.

Washington, D.C. 20549-6010

Attn: Pearlyne Paulemon

Brigitte Lippmann

Division of Corporate Finance

Office of Real Estate & Construction

Re: SKK Holdings Limited (the “Company”)

Registration Statement on Form F-1 (Registration No. 333-276744)

Request for Acceleration of Effective Date

Ladies and gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, Bancroft Capital, LLC, as sole underwriter, hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it will become effective at 4:30 p.m., Eastern Time, on March 27, 2024, or as soon thereafter as practicable, or at such later time as the Company or its counsel may request via telephone call to the staff.

Pursuant to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

Very truly yours,
Bancroft Capital, LLC

Show Raw Text
CORRESP
1
filename1.htm

March
25, 2024

VIA
EDGAR TRANSMISSION

Division
of Corporate Finance

United
States Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549-6010

  Attn:
  Pearlyne Paulemon

  Brigitte Lippmann

  Division of Corporate Finance

  Office of Real Estate & Construction

  Re:
  SKK Holdings Limited (the “Company”)

  Registration Statement on Form F-1 (Registration No.
  333-276744)

  Request for Acceleration of Effective Date

Ladies
and gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as
amended, Bancroft Capital, LLC, as sole underwriter, hereby requests acceleration of the effective date of the above-referenced Registration
Statement so that it will become effective at 4:30 p.m., Eastern Time, on March 27, 2024,
or as soon thereafter as practicable, or at such later time as the Company or its counsel may request via telephone call to the staff.

Pursuant
to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably
anticipated to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus
as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The
undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange
Act of 1934, as amended.

    Very truly yours,

    Bancroft Capital, LLC

    By:
    /s/ Robert L. Malin

    Name:
    Robert L. Malin

    Title:
    Managing Director

    cc:
    Mitchell Goldsmith, Esq., Taft Stettinius
    & Hollister LLP

    Alan Gilbert, Esq., Taft Stettinius & Hollister
    LLP