SEC Comment Letter 0000000000-24-005468 to SUPER HI INTERNATIONAL HOLDING LTD. (HDL, SPHIF) (CIK 0001995306) (HDL)
SUPER HI INTERNATIONAL HOLDING LTD. (HDL, SPHIF) (CIK 0001995306)
Date: May 14, 2024 · CIK: 0001995306 · Accession: 0000000000-24-005468
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File numbers found in text: 333-278940
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United States securities and exchange commission logo
May 14, 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. 1 to Registration Statement on Form F-1
Filed May 13, 2024
File No. 333-278940
Dear Cong Qu:
We have reviewed your amended registration statement and have the following
comment(s).
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. 1 to Registration Statement on Form F-1
Recent Developments, page 14
1.In your presentation of unaudited consolidated statement of profit or loss data and selected
operating data for the three months ended March 31, 2024, you direct readers to
“Management’s Discussion and Analysis of Financial Condition and Results of
Operations” for information regarding trends and other factors, including seasonality, that
may influence your results of operations and for recent quarterly operating results.
However, you have not included a discussion of these results under "Management's
Discussion and Analysis of Financial Condition and Results of Operations" or in your
financial statements. Revise to clarify, if true, that these results are preliminary in nature
and to state that your financial and closing procedures for the period ended March 31,
2024 have not yet been completed. Disclose when you anticipate your financial statements
for the quarter ending March 31, 2024 will be available. Revise to provide qualitative
FirstName LastNameCong Qu
Comapany NameSUPER HI INTERNATIONAL HOLDING LTD.
May 14, 2024 Page 2
FirstName LastName
Cong Qu
SUPER HI INTERNATIONAL HOLDING LTD.
May 14, 2024
Page 2
disclosure about how such results impact your trends disclosure provided elsewhere.
Alternatively, if these results are not preliminary in nature, revise to include a discussion
of such results in your "Management's Discussion and Analysis of Financial Condition
and Results of Operations" and update your financial statements.
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: Ming Kong