SEC Company Response from Kepler Group (KPL) — Dec 5, 2025
Kepler Group Ltd
Date: Dec. 5, 2025 · CIK: 0002000208 · Accession: 0001493152-25-026377
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-290005
Referenced dates: December 3, 2025
Letter
Via Edgar Division of Corporation Finance Office of Finance Re: Kepler Group Limited (the " Company ") Amendment No. 1 to Registration Statement on Form F-1 Filed October 8, 2025 File No. 333-290005
Dear SEC Officers:
We hereby provide a response to the comment issued in a letter dated December 3, 2025 (the " Staff's Letter ") regarding the Company's Amendment No. 1 to Registration Statement on Form F-1 (the " Form F-1 "). Contemporaneously, we are filing the revised Form F-1 via Edgar (the " Amended F-1 ").
In order to facilitate the review by the Commission's staff (the " Staff ") of the Amended F-1, we have responded to the comments set forth in the Staff's Letter on a point-by-point basis. The numbered paragraph sets forth below responds to the Staff's comment and corresponds to the numbered paragraph in the Staff's Letter.
Amendment No. 1 to Registration Statement on Form F-1
Exhibits
1. Several of your exhibits were submitted as images and therefore are not text searchable, including Exhibits 3.1, 3.2, 8.1, 10.1-10.3 and 10.6. File an amendment to include revised versions of the exhibits filed in a format that permits the contents to be text searchable.
Response: We respectfully advise the Staff that we have revised Exhibits 3.1, 3.2, 8.1, 10.1-10.3 and 10.6 to provide text searchable versions.
Please reach Lawrence Venick, the Company's outside counsel at +852.5600.0188 if you would like additional information with respect to any of the foregoing. Thank you.
Sincerely,
/s/
Kwok Yu Hin
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CORRESP 1 filename1.htm KEPLER GROUP LIMITED Suite 3902-03, 39/F Tower 6, The Gateway Harbour City, Tsim Sha Tsui Hong Kong Via Edgar December 5, 2025 Division of Corporation Finance Office of Finance U.S. Securities & Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: Kepler Group Limited (the " Company ") Amendment No. 1 to Registration Statement on Form F-1 Filed October 8, 2025 File No. 333-290005 Dear SEC Officers: We hereby provide a response to the comment issued in a letter dated December 3, 2025 (the " Staff's Letter ") regarding the Company's Amendment No. 1 to Registration Statement on Form F-1 (the " Form F-1 "). Contemporaneously, we are filing the revised Form F-1 via Edgar (the " Amended F-1 "). In order to facilitate the review by the Commission's staff (the " Staff ") of the Amended F-1, we have responded to the comments set forth in the Staff's Letter on a point-by-point basis. The numbered paragraph sets forth below responds to the Staff's comment and corresponds to the numbered paragraph in the Staff's Letter. Amendment No. 1 to Registration Statement on Form F-1 Exhibits 1. Several of your exhibits were submitted as images and therefore are not text searchable, including Exhibits 3.1, 3.2, 8.1, 10.1-10.3 and 10.6. File an amendment to include revised versions of the exhibits filed in a format that permits the contents to be text searchable. Response: We respectfully advise the Staff that we have revised Exhibits 3.1, 3.2, 8.1, 10.1-10.3 and 10.6 to provide text searchable versions. Please reach Lawrence Venick, the Company's outside counsel at +852.5600.0188 if you would like additional information with respect to any of the foregoing. Thank you. Sincerely, /s/ Kwok Yu Hin Kepler Group Limited Chief Executive Officer Encl.