SEC Comment Letter 0000000000-24-007128 to Fashionista Distributor Holdings Inc. (CIK 0002004256)
Fashionista Distributor Holdings Inc. (CIK 0002004256)
Date: June 24, 2024 · CIK: 0002004256 · Accession: 0000000000-24-007128
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File numbers found in text: 333-277616
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United States securities and exchange commission logo
June 24, 2024
Yushun Ting
President and Chief Executive Officer
Fashionista Distributor Holdings Inc.
2F., No. 24, Sec.1, Chongqing N. Rd., Datong Dist.
Taipei City, Taiwan (R.O.C) 103
Re:Fashionista Distributor Holdings Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed June 13, 2024
File No. 333-277616
Dear Yushun Ting:
We have reviewed your amended registration statement and have the following
comment(s).
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. Unless we note otherwise,
any references to prior comments are to comments in our June 6, 2024 letter.
Amendment No. 2 to Registration Statement on Form S-1
Risk Factors
We depend on a few major customers..., page 7
1.We note your revised disclosure in response to prior comment 1 in which you state that as
of the date of the prospectus the revenues associated with the mentioned six new
agreements have been recognized. It appears from the narrative description of these
agreements that the work associated with them has yet to be performed. Please clarify the
status of the work to be performed for these agreements. If the work is not complete for
one or more of these agreements, explain to us your basis for recognizing the associated
revenue.
FirstName LastNameYushun Ting
Comapany NameFashionista Distributor Holdings Inc.
June 24, 2024 Page 2
FirstName LastName
Yushun Ting
Fashionista Distributor Holdings Inc.
June 24, 2024
Page 2
Please contact Aamira Chaudhry at 202-551-3389 or Doug Jones at 202-551-3309 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alyssa Wall at 202-551-8106 or Mara Ransom at 202-551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Wei Wang