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SEC Comment Letter 0000000000-24-013691 to 3 E Network Technology Group Ltd (MASK)

3 E Network Technology Group Ltd
Date: Dec. 12, 2024 · CIK: 0001993097 · Accession: 0000000000-24-013691

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File numbers found in text: 333-276180

Date
December 12, 2024
Author
Office of Technology
Form
UPLOAD
Company
3 E Network Technology Group Ltd

Letter

December 12, 2024 Ye Tao Chief Executive Officer 3 E Network Technology Group Limited B046 of Room 801, 11 Sixing Street Huangge Town, Nansha District Guangzhou, Guangdong Province, PRC Re:3 E Network Technology Group Limited Amendment No. 4 to Registration Statement on Form F-1 Filed December 4, 2024 File No. 333-276180 Dear Ye Tao: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Amendment No. 4 to Registration Statement on Form F-1 Dilution, page 70 1.We are unable to recalculate the net tangible book value after the offering. Please reconcile, in your response, the net tangible book value in dollars before the offering to the net tangible book value after the offering. As part of your response, please tell us how deferred IPO costs are considered in your calculations.

December 12, 2024 Page 2 Please contact Chris Dietz at 202-551-3408 if you have questions regarding comments on the financial statements and related matters. Please contact Mariam Mansaray at 202-551-6356 or Jan Woo at 202-551-3453 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc:Richard J. Chang, Esq.

Show Raw Text
December 12, 2024
Ye Tao
Chief Executive Officer
3 E Network Technology Group Limited
B046 of Room 801, 11 Sixing Street
Huangge Town, Nansha District
Guangzhou, Guangdong Province, PRC
Re:3 E Network Technology Group Limited
Amendment No. 4 to Registration Statement on Form F-1
Filed December 4, 2024
File No. 333-276180
Dear Ye Tao:
            We have reviewed your amended registration statement and have the following
comment.
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Amendment No. 4 to Registration Statement on Form F-1
Dilution, page 70
1.We are unable to recalculate the net tangible book value after the offering. Please
reconcile, in your response, the net tangible book value in dollars before the
offering to the net tangible book value after the offering. As part of your response,
please tell us how deferred IPO costs are considered in your calculations.

December 12, 2024
Page 2
            Please contact Chris Dietz at 202-551-3408 if you have questions regarding
comments on the financial statements and related matters. Please contact Mariam Mansaray
at 202-551-6356 or Jan Woo at 202-551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Richard J. Chang, Esq.