SEC Comment Letter 0000000000-24-010503 to BrilliA Inc (BRIA)
BrilliA Inc
Date: Sept. 17, 2024 · CIK: 0002000230 · Accession: 0000000000-24-010503
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-282056
Letter
September 17, 2024 Kendrew Hartanto Chief Executive Officer BrilliA Inc 220 Orchard Road Unit 05-01, Midpoint Orchard Singapore 238852 Re:BrilliA Inc Registration Statement on Form F-1 Filed September 12, 2024 File No. 333-282056 Dear Kendrew Hartanto: We have reviewed your 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 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. Form F-1 filed September 12, 2024 Exhibits 1.Please request counsel to remove assumption 2.11 from the legal opinion filed as Exhibit 5.1. It is not appropriate for counsel to assume that the company is not in bankruptcy. For more information, refer to Section II.B.3.a. of Staff Legal Bulletin No. 19. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.
September 17, 2024 Page 2 Please contact Beverly Singleton at 202-551-3328 or Kevin Stertzel at 202-551-3723 if you have questions regarding comments on the financial statements and related matters. Please contact Erin Donahue at 202-551-6063 or Jennifer Angelini at 202-551-3047 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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September 17, 2024
Kendrew Hartanto
Chief Executive Officer
BrilliA Inc
220 Orchard Road
Unit 05-01, Midpoint Orchard
Singapore 238852
Re:BrilliA Inc
Registration Statement on Form F-1
Filed September 12, 2024
File No. 333-282056
Dear Kendrew Hartanto:
We have reviewed your 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 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.
Form F-1 filed September 12, 2024
Exhibits
1.Please request counsel to remove assumption 2.11 from the legal opinion filed as Exhibit
5.1. It is not appropriate for counsel to assume that the company is not in bankruptcy. For
more information, refer to Section II.B.3.a. of Staff Legal Bulletin No. 19.
We remind you that the company and its management are responsible for the accuracy and
adequacy of their disclosures, notwithstanding any review, comments, action or absence of action
by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
September 17, 2024
Page 2
Please contact Beverly Singleton at 202-551-3328 or Kevin Stertzel at 202-551-3723 if
you have questions regarding comments on the financial statements and related matters. Please
contact Erin Donahue at 202-551-6063 or Jennifer Angelini at 202-551-3047 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing