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Correspondence 0001104659-24-052337 from SUPER HI INTERNATIONAL HOLDING LTD. (HDL, SPHIF) (CIK 0001995306) (HDL)

SUPER HI INTERNATIONAL HOLDING LTD. (HDL, SPHIF) (CIK 0001995306)
Date: April 26, 2024 · CIK: 0001995306 · Accession: 0001104659-24-052337

AI Filing Summary & Sentiment

Date
April 26, 2024
Author
/s/
Form
CORRESP
Company
SUPER HI INTERNATIONAL HOLDING LTD. (HDL, SPHIF) (CIK 0001995306)

Letter

Division of Corporation Finance Office of Trade & Services 100 F Street, NE Washington, D.C. 20549 Re: SUPER HI INTERNATIONAL HOLDING LTD. (CIK No. 0001995306) Registration Statement on Form F-1

Dear Mr. Kuhn, Mr. Decker, Ms. Pandit and Ms. Peyser:

On behalf of our client, SUPER HI INTERNATIONAL HOLDING LTD., a company organized under the laws of the Cayman Islands (the “Company”), we are filing herewith the Company’s registration statement on Form F-1 (the “Registration Statement”) and certain exhibits via EDGAR to the Securities and Exchange Commission (the “Commission”).

Pursuant to the Jumpstart Our Business Startups Act, as amended (the “JOBS Act”), the Company is, concurrently with the filing of the Registration Statement, also filing the draft registration statement and all amendments thereto that were previously submitted for the non-public review of the staff (the “Staff”) of the Commission.

The Company plans to commence the road show no earlier than 15 days after the date hereof pursuant to the JOBS Act. The Company would appreciate the Staff’s timely assistance and support to the Company in meeting the proposed timetable for the offering.

* * *

U.S. Securities and Exchange Commission

April 26, 2024

Page 2

If you have any questions regarding the Registration Statement, please contact Mengyu Lu by phone at +852 3761 3421 or via e-mail at mengyu.lu@kirkland.com; Ming Kong by phone at +852 3761 3578 or via e-mail at ming.kong@kirkland.com; Samantha Peng by phone at +852 3761 3423 or via e-mail at samantha.peng@kirkland.com; or Kong Lai San, partner at Deloitte & Touche LLP, by telephone at +65 6531 5068 or via email at lakong@deloitte.com. Deloitte & Touche LLP is the independent registered public accounting firm of the Company.

Sincerely,
/s/
Mengyu Lu

Show Raw Text
CORRESP
1
filename1.htm

                           26th Floor, Gloucester Tower

    The Landmark

    15 Queen’s Road Central

    Hong Kong

    Telephone: +852 3761 3300

    Facsimile: +852 3761 3301

    www.kirkland.com

    April 26, 2024

    Mr. Patrick Kuhn

 Mr. Rufus Decker

    Ms. Rucha Pandit

 Ms. Lilyanna Peyser

 Division of Corporation Finance

 Office of Trade & Services

 U.S. Securities
    and Exchange Commission

 100 F Street, NE

 Washington, D.C. 20549

 Re: SUPER HI INTERNATIONAL HOLDING
                                            LTD. (CIK No. 0001995306)

Registration Statement on Form F-1

Dear Mr. Kuhn, Mr. Decker, Ms. Pandit
and Ms. Peyser:

On behalf of our client,
SUPER HI INTERNATIONAL HOLDING LTD., a company organized under the laws of the Cayman Islands (the “Company”), we are filing
herewith the Company’s registration statement on Form F-1 (the “Registration Statement”) and certain exhibits
via EDGAR to the Securities and Exchange Commission (the “Commission”).

Pursuant to the Jumpstart
Our Business Startups Act, as amended (the “JOBS Act”), the Company is, concurrently with the filing of the Registration
Statement, also filing the draft registration statement and all amendments thereto that were previously submitted for the non-public
review of the staff (the “Staff”) of the Commission.

The Company plans to commence
the road show no earlier than 15 days after the date hereof pursuant to the JOBS Act. The Company would appreciate the Staff’s
timely assistance and support to the Company in meeting the proposed timetable for the offering.

*          *          *

U.S.
Securities and Exchange Commission

April 26, 2024

Page 2

If you have any questions
regarding the Registration Statement, please contact Mengyu Lu by phone at +852 3761 3421 or via e-mail at mengyu.lu@kirkland.com; Ming
Kong by phone at +852 3761 3578 or via e-mail at ming.kong@kirkland.com; Samantha Peng by phone at +852 3761 3423 or via e-mail at samantha.peng@kirkland.com;
or Kong Lai San, partner at Deloitte & Touche LLP, by telephone at +65 6531 5068 or via email at lakong@deloitte.com. Deloitte &
Touche LLP is the independent registered public accounting firm of the Company.

  Sincerely,

  /s/
  Mengyu Lu

  Mengyu Lu

Enclosures

cc:           Ping
Shu, Director and Chairman, SUPER HI INTERNATIONAL HOLDING LTD.

Cong Qu, Financial Director,
SUPER HI INTERNATIONAL HOLDING LTD.

Ming Kong, Esq., Partner,
Kirkland & Ellis International LLP

Samantha Peng, Esq.,
Partner, Kirkland & Ellis International LLP

Ashlee Wu, Esq., Partner,
Kirkland & Ellis International LLP

Kong Lai San, Partner, Deloitte &
Touche LLP

Raymond Li, Esq., Partner,
Paul Hastings, LLP

Chris DeCresce, Esq.,
Partner, Paul Hastings, LLP