SEC Comment Letter 0000000000-24-001394 to Cuprina Holdings (Cayman) LTD (CUPR)
Cuprina Holdings (Cayman) LTD
Date: Feb. 5, 2024 · CIK: 0001995704 · Accession: 0000000000-24-001394
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo February 5, 2024 David Quek Yong Qi Chief Executive Officer Cuprina Holdings (Cayman) Limited Blk 1090 Lower Delta Road #06-08 Singapore 169201 Re:Cuprina Holdings (Cayman) Limited Amendment No. 3 to Draft Registration Statement on Form F-1 Submitted January 26, 2024 CIK No. 0001995704 Dear David Quek Yong Qi: We have reviewed your amended draft registration statement and have the following comments. 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 December 28, 2023 letter. Amendment No. 3 to Draft Registration Statement on Form F-1 Management Compensation of Directors and Executive Officers, page 134 1.Please revise this section to provide compensation information for the year ended December 31, 2023. Notes to Consolidated Financial Statements 1 - Organization and business overview Reorganization of the Company's legal structure (the "Reorganization"), page F-7 2.Please clarify your disclosure that the Reorganization resulted in a change in reporting
FirstName LastNameDavid Quek Yong Qi Comapany NameCuprina Holdings (Cayman) Limited February 5, 2024 Page 2 FirstName LastName David Quek Yong Qi Cuprina Holdings (Cayman) Limited February 5, 2024 Page 2 entity from Cuprina Pte. Ltd to Cuprina Holdings (Cayman) Limited as the financial statements including in your prior submissions were labeled as those of Cuprina Holdings (Cayman) Limited. Please also clarify if this is the reason for the changes to the issued and outstanding share capital of Cuprina Holdings (Cayman) Limited. In this regard, we note that your initial and outstanding share capital consisted of one Class A Ordinary Share prior to the Reorganization and now consists of 3,915,000 Class A Ordinary Shares and 14,085,000 Class B Ordinary Shares after the Reorganization. If the change in reporting entity is not the reason for the change in share capital, please disclose the reasons for these changes. Please contact Christine Torney at 202-551-3652 or Angela Connell at 202-551-3426 if you have questions regarding comments on the financial statements and related matters. Please contact Doris Stacey Gama at 202-551-3188 or Alan Campbell at 202-551-4224 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Mathew Lewis, Esq.
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United States securities and exchange commission logo
February 5, 2024
David Quek Yong Qi
Chief Executive Officer
Cuprina Holdings (Cayman) Limited
Blk 1090 Lower Delta Road #06-08
Singapore 169201
Re:Cuprina Holdings (Cayman) Limited
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted January 26, 2024
CIK No. 0001995704
Dear David Quek Yong Qi:
We have reviewed your amended draft registration statement and have the following
comments.
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
December 28, 2023 letter.
Amendment No. 3 to Draft Registration Statement on Form F-1
Management
Compensation of Directors and Executive Officers, page 134
1.Please revise this section to provide compensation information for the year ended
December 31, 2023.
Notes to Consolidated Financial Statements
1 - Organization and business overview
Reorganization of the Company's legal structure (the "Reorganization"), page F-7
2.Please clarify your disclosure that the Reorganization resulted in a change in reporting
FirstName LastNameDavid Quek Yong Qi
Comapany NameCuprina Holdings (Cayman) Limited
February 5, 2024 Page 2
FirstName LastName
David Quek Yong Qi
Cuprina Holdings (Cayman) Limited
February 5, 2024
Page 2
entity from Cuprina Pte. Ltd to Cuprina Holdings (Cayman) Limited as the financial
statements including in your prior submissions were labeled as those of Cuprina Holdings
(Cayman) Limited. Please also clarify if this is the reason for the changes to the issued and
outstanding share capital of Cuprina Holdings (Cayman) Limited. In this regard, we note
that your initial and outstanding share capital consisted of one Class A Ordinary Share
prior to the Reorganization and now consists of 3,915,000 Class A Ordinary Shares and
14,085,000 Class B Ordinary Shares after the Reorganization. If the change in reporting
entity is not the reason for the change in share capital, please disclose the reasons for these
changes.
Please contact Christine Torney at 202-551-3652 or Angela Connell at 202-551-3426 if
you have questions regarding comments on the financial statements and related matters. Please
contact Doris Stacey Gama at 202-551-3188 or Alan Campbell at 202-551-4224 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Mathew Lewis, Esq.