SEC Comment Letter 0000000000-24-003526 to SUPER HI INTERNATIONAL HOLDING LTD. (HDL, SPHIF) (CIK 0001995306) (HDL)
SUPER HI INTERNATIONAL HOLDING LTD. (HDL, SPHIF) (CIK 0001995306)
Date: April 2, 2024 · CIK: 0001995306 · Accession: 0000000000-24-003526
AI Filing Summary & Sentiment
Reasoning
Letter
United States securities and exchange commission logo April 2, 2024 Cong Qu Financial Director SUPER HI INTERNATIONAL HOLDING LTD. 1 Paya Lebar Link, #09-04 PLQ 1 Paya Lebar Quarter Singapore 408533 Re:SUPER HI INTERNATIONAL HOLDING LTD. Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted March 8, 2024 CIK No. 0001995306 Dear Cong Qu: We have reviewed your amended draft registration statement and have the following comment(s). 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. Unless we note otherwise, any references to prior comments are to comments in our February 23, 2024 letter. Amendment No. 2 to Draft Registration Statement on Form F-1 General 1.We note your response to prior comment 6 and reissue it in part. Please further revise the relevant risk factor on page 37 as well as the "Enforceability of Civil Liabilities" section to clearly identify the executive officer who resides in mainland China.
FirstName LastNameCong Qu Comapany NameSUPER HI INTERNATIONAL HOLDING LTD. April 2, 2024 Page 2 FirstName LastName Cong Qu SUPER HI INTERNATIONAL HOLDING LTD. April 2, 2024 Page 2 Please contact Rucha Pandit at 202-551-6022 or Mara Ransom at 202-551-3264 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Dr. Mengyu Lu
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United States securities and exchange commission logo
April 2, 2024
Cong Qu
Financial Director
SUPER HI INTERNATIONAL HOLDING LTD.
1 Paya Lebar Link, #09-04
PLQ 1 Paya Lebar Quarter
Singapore 408533
Re:SUPER HI INTERNATIONAL HOLDING LTD.
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted March 8, 2024
CIK No. 0001995306
Dear Cong Qu:
We have reviewed your amended draft registration statement and have the following
comment(s).
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. Unless we note otherwise, any references to prior comments are to comments in our
February 23, 2024 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1
General
1.We note your response to prior comment 6 and reissue it in part. Please further revise the
relevant risk factor on page 37 as well as the "Enforceability of Civil Liabilities" section
to clearly identify the executive officer who resides in mainland China.
FirstName LastNameCong Qu
Comapany NameSUPER HI INTERNATIONAL HOLDING LTD.
April 2, 2024 Page 2
FirstName LastName
Cong Qu
SUPER HI INTERNATIONAL HOLDING LTD.
April 2, 2024
Page 2
Please contact Rucha Pandit at 202-551-6022 or Mara Ransom at 202-551-3264 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Dr. Mengyu Lu