CORRESP Filing
Empro Group Inc.
Date: May 27, 2025 · CIK: 0002005569 · Accession: 0001641172-25-012432
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-282155
Referenced dates: May 23, 2025
Letter
Division of Corporation Finance Office of Industrial Applications and Services RE: Empro Group Inc. Amendment No. 9 to Registration Statement on Form F-1 Filed May 22, 2025 File No. 333-282155
Dear Sir / Madam:
On behalf of our client, Empro Group Inc. (the " Company "), a Cayman Islands exempted company with limited liability, we hereby submit this letter in response to the comments set forth in that certain letter dated May 23, 2025 from the staff (the " Staff ") of the U.S. Securities and Exchange Commission (the " Commission ") to the Company, relating to Amendment No. 9 to the Registration Statement on Form F-1 that the Company filed with the Commission on May 22, 2025.
The Company is responding to the Staff's comments by submitting this letter, which addresses the Staff's comments, as more fully set forth below, and by hereby filing Amendment No. 10 to the Registration Statement (" Amendment No. 10 "). For your convenience, the Staff's comments have been retyped herein in bold.
Comment Report of Independent Accountants, page F-2
We note that you restated earnings per share in response to comment 1. Please address the following:
● Appropriately label the impacted financial statements as restated.
● Provide the disclosures required by paragraph 49 of IAS 8.
● Request UHY Malaysia PLT to include a paragraph regarding the restatement in its report and to appropriately date its report. See paragraph 18e of PCAOB Auditing Standard 3101 and Auditing Standard 3110.
● Ensure that the amendment includes an updated consent that refers to the revised audit report.
Response
In response to the comment, we have revised the disclosures contained in Amendment No. 10 to: (A) label the financial statements as restated; (B) provide the disclosures required by paragraph 49 of IAS 8; (C) include a paragraph regarding the restatement in the audit report; and (D) change the date of the audit report to May 26, 2025. We also have included as Exhibit 23.1 an updated consent that refers to the revised audit report.
If you have any further questions or comments, or would like to discuss this response letter, please feel free to call the undersigned at (212) 326-0468 or to email the undersigned at mcampoli@pryorcashman.com .
Sincerely,
Michael
T. Campoli
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CORRESP
1
filename1.htm
BY
EDGAR
May
27, 2025
U.S.
Securities and Exchange Commission
Division
of Corporation Finance
Office
of Industrial Applications and Services
Washington,
D.C. 20549
Attn:
Robert
Augustin
Katherine
Bagley
RE:
Empro
Group Inc.
Amendment
No. 9 to Registration Statement on Form F-1
Filed
May 22, 2025
File
No. 333-282155
Dear
Sir / Madam:
On
behalf of our client, Empro Group Inc. (the " Company "), a Cayman Islands exempted company with limited liability,
we hereby submit this letter in response to the comments set forth in that certain letter dated May 23, 2025 from the staff (the " Staff ")
of the U.S. Securities and Exchange Commission (the " Commission ") to the Company, relating to Amendment No. 9 to the
Registration Statement on Form F-1 that the Company filed with the Commission on May 22, 2025.
The
Company is responding to the Staff's comments by submitting this letter, which addresses the Staff's comments, as more fully
set forth below, and by hereby filing Amendment No. 10 to the Registration Statement (" Amendment No. 10 "). For your
convenience, the Staff's comments have been retyped herein in bold.
Comment
1
Report
of Independent Accountants, page F-2
We
note that you restated earnings per share in response to comment 1. Please address the following:
●
Appropriately
label the impacted financial statements as restated.
●
Provide
the disclosures required by paragraph 49 of IAS 8.
●
Request
UHY Malaysia PLT to include a paragraph regarding the restatement in its report and to appropriately date its report. See paragraph
18e of PCAOB Auditing Standard 3101 and Auditing Standard 3110.
●
Ensure
that the amendment includes an updated consent that refers to the revised audit report.
Response
In
response to the comment, we have revised the disclosures contained in Amendment No. 10 to: (A) label the financial statements as restated;
(B) provide the disclosures required by paragraph 49 of IAS 8; (C) include a paragraph regarding the restatement in the audit report;
and (D) change the date of the audit report to May 26, 2025. We also have included as Exhibit 23.1 an updated consent that refers
to the revised audit report.
If
you have any further questions or comments, or would like to discuss this response letter, please feel free to call the undersigned at
(212) 326-0468 or to email the undersigned at mcampoli@pryorcashman.com .
Sincerely,
Michael
T. Campoli
Michael
T. Campoli
Pryor
Cashman LLP
cc:
Yeoh
Chee Wei