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SEC Comment Letter 0000000000-25-001159 to Empro Group Inc. (EMPG)

Empro Group Inc.
Date: Feb. 3, 2025 · CIK: 0002005569 · Accession: 0000000000-25-001159

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File numbers found in text: 333-282155

Date
February 3, 2025
Author
Yeoh Chee Wei
Form
UPLOAD
Company
Empro Group Inc.

Letter

February 3, 2025 Yeoh Chee Wei Chief Executive Officer Empro Group Inc. 21, Jalan 15/23, Tiong Nam Industry Park, 40200 Shah Alam Selangor, Malaysia Re:Empro Group Inc. Amendment No. 4 to Registration Statement on Form F-1 Filed January 22, 2025 File No. 333-282155 Dear Yeoh Chee Wei: 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 December 23, 2024 letter. Amendment No. 4 to Registration Statement on Form F-1 filed January 22, 2025 Financial Statements, page F-1 1.We note the audited financial statements of EMP Solution Sdn. Bhd. are older than 12 months. Please update your financial statements and related disclosures pursuant to Item 4.a. of Form F-1 and Item 8.A.4 of Form 20-F or, if applicable, provide the appropriate representations required by Instruction 2 to Item 8.A.4 of Form 20-F in an exhibit to the filing.

February 3, 2025 Page 2 Please contact Al Pavot at 202-551-3738 or Jeanne Baker at 202-551-3691 if you have questions regarding comments on the financial statements and related matters. Please contact Robert Augustin at 202-551-8483 or Katherine Bagley at 202-551-2545 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc:Michael T. Campoli

Show Raw Text
February 3, 2025
Yeoh Chee Wei
Chief Executive Officer
Empro Group Inc.
21, Jalan 15/23, Tiong Nam Industry Park, 40200 Shah Alam
Selangor, Malaysia
Re:Empro Group Inc.
Amendment No. 4 to Registration Statement on Form F-1
Filed January 22, 2025
File No. 333-282155
Dear Yeoh Chee Wei:
            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 December 23, 2024
letter.
Amendment No. 4 to Registration Statement on Form F-1 filed January 22, 2025
Financial Statements, page F-1
1.We note the audited financial statements of EMP Solution Sdn. Bhd. are older than 12
months. Please update your financial statements and related disclosures pursuant to
Item 4.a. of Form F-1 and Item 8.A.4 of Form 20-F or, if applicable, provide the
appropriate representations required by Instruction 2 to Item 8.A.4 of Form 20-F in an
exhibit to the filing.

February 3, 2025
Page 2
            Please contact Al Pavot at 202-551-3738 or Jeanne Baker at 202-551-3691 if you
have questions regarding comments on the financial statements and related matters. Please
contact Robert Augustin at 202-551-8483 or Katherine Bagley at 202-551-2545 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Michael T. Campoli