SEC Comment Letter 0000000000-24-007306 to Cuprina Holdings (Cayman) LTD (CUPR)
Cuprina Holdings (Cayman) LTD
Date: June 28, 2024 · CIK: 0001995704 · Accession: 0000000000-24-007306
AI Filing Summary & Sentiment
File numbers found in text: 333-277731
Letter
United States securities and exchange commission logo June 28, 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 Registration Statement on Form F-1 Filed June 20, 2024 File No. 333-277731 Dear David Quek Yong Qi: 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 our 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. 3 to Registration Statement on Form F-1 General 1.We continue to consider your analysis regarding Securities Act Rules Compliance and Disclosure Interpretation 612.09. In that regard, we note your disclosure at page II-1 that the shareholders received the shares that they seek to resell in consideration for ordinary shares of Cuprina Holdings (BVI) Limited. Please explain the circumstances surrounding their receipt of the shares of Cuprina Holdings (BVI) Limited, including, but not limited to, the timing of the issuance and any consideration provided and, in light of your disclosure at page F-23, the terms of any share subscriptions. Please also clarify whether these shareholders held any shares in Cuprina Holding Pte. Ltd. before the reorganization and, if so, describe the circumstances surrounding the issuance of those shares.
FirstName LastNameDavid Quek Yong Qi Comapany NameCuprina Holdings (Cayman) Limited June 28, 2024 Page 2 FirstName LastName David Quek Yong Qi Cuprina Holdings (Cayman) Limited June 28, 2024 Page 2 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.
Show Raw Text
United States securities and exchange commission logo
June 28, 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 Registration Statement on Form F-1
Filed June 20, 2024
File No. 333-277731
Dear David Quek Yong Qi:
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 our 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. 3 to Registration Statement on Form F-1
General
1.We continue to consider your analysis regarding Securities Act Rules Compliance and
Disclosure Interpretation 612.09. In that regard, we note your disclosure at page II-1 that
the shareholders received the shares that they seek to resell in consideration for ordinary
shares of Cuprina Holdings (BVI) Limited. Please explain the circumstances surrounding
their receipt of the shares of Cuprina Holdings (BVI) Limited, including, but not limited
to, the timing of the issuance and any consideration provided and, in light of your
disclosure at page F-23, the terms of any share subscriptions. Please also clarify whether
these shareholders held any shares in Cuprina Holding Pte. Ltd. before the reorganization
and, if so, describe the circumstances surrounding the issuance of those shares.
FirstName LastNameDavid Quek Yong Qi
Comapany NameCuprina Holdings (Cayman) Limited
June 28, 2024 Page 2
FirstName LastName
David Quek Yong Qi
Cuprina Holdings (Cayman) Limited
June 28, 2024
Page 2
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.