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Correspondence 0001213900-24-079530 from Concorde International Group Ltd. (CIGL)

Concorde International Group Ltd.
Date: Sept. 17, 2024 · CIK: 0002001794 · Accession: 0001213900-24-079530

AI Filing Summary & Sentiment

File numbers found in text: 333-281799

Referenced dates: September 11, 2024

Date
September 17, 2024
Author
Not clearly detected
Form
CORRESP
Company
Concorde International Group Ltd.

Letter

CONCORDE INTERNATIONAL GROUP LTD

3 Ang Mo Kio Street 62, #01-49 LINK@AMK

Singapore 569139

September 17, 2024

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

Attn: Scott Stringer

Angela Lumley

Jenna Hough

Dietrich King

Re: Concorde International Group Ltd.

Registration Statement on Form F-1

Filed August 27, 2024

File No. 333-281799

Ladies and Gentlemen:

We hereby submit the responses of Concorde International Group Ltd. (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated September 11, 2024, providing the Staff’s comments with respect to the Company’s Registration Statement on Form F-1 filed on August 27, 2024. Concurrently with the submission of this letter, the Company is submitting an Amendment No.1 to Registration Statement (the “Amendment No.1”) on Form F-1 via EDGAR with the Commission.

For the convenience of the Staff, each of the Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.

Registration Statement on Form F-1 filed August 27, 2024

Use of Proceeds, page 32

1. We note your disclosure of how you plan to use the net proceeds totaling $5,000,000 appears to be inconsistent with your disclosure of the expected net proceeds of $4,400,000. Please clarify or revise.

RESPONSE: In response to the Staff’s comments, we have revised the Use of Proceeds section on page 32.

Dilution, page 35

2. The dilution amount of $4.20 in net tangible book value to new investors in the offering appears to be inconsistent with the initial public offering price less the pro forma net tangible book value per share. Please clarify or revise.

RESPONSE: In response to the Staff’s comments, we have revised the dilution amount to $3.68 and updated the related disclosure on page 35.

If you would like to discuss any of the responses to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at +65 2960802 or Louis A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

Sincerely,
Concorde International Group Ltd.

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CORRESP
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CONCORDE INTERNATIONAL GROUP LTD

3 Ang Mo Kio Street 62, #01-49 LINK@AMK

Singapore 569139

September 17, 2024

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Scott Stringer

    Angela Lumley

    Jenna Hough

    Dietrich King

    Re:
    Concorde International Group Ltd.

    Registration Statement on Form F-1

    Filed August 27, 2024

    File No. 333-281799

Ladies and Gentlemen:

We hereby submit the responses of Concorde
International Group Ltd. (the “Company”) to the comments of the staff (the “Staff”) of the U.S.
Securities and Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated September 11, 2024,
providing the Staff’s comments with respect to the Company’s Registration Statement on Form F-1 filed on August 27, 2024.
Concurrently with the submission of this letter, the Company is submitting an Amendment No.1 to Registration Statement (the “Amendment
No.1”) on Form F-1 via EDGAR with the Commission.

For the convenience of the Staff, each
of the Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise,
references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.

Registration Statement on Form F-1 filed August 27, 2024

Use of Proceeds, page 32

 1. We note your disclosure of how you plan to use the net proceeds totaling $5,000,000
appears to be inconsistent with your disclosure of the expected net proceeds of $4,400,000. Please clarify or revise.

RESPONSE:
In response to the Staff’s comments, we have revised the Use of Proceeds section on page 32.

Dilution, page 35

 2. The dilution amount of $4.20 in net tangible book value to new investors in the
offering appears to be inconsistent with the initial public offering price less the pro forma net tangible book value per share. Please
clarify or revise.

RESPONSE:
In response to the Staff’s comments, we have revised the dilution amount to $3.68 and updated the related disclosure on page
35.

If you would like to discuss any of the responses
to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at +65 2960802 or Louis
A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    Concorde International Group Ltd.

    By:
    /s/ Swee Kheng Chua

    Name:
    Swee Kheng Chua

    Title:
    Chief Executive Officer

cc: Louis A. Bevilacqua, Esq., Bevilacqua PLLC