SEC Company Response from HCYC Holding Co (CIK 0002006779) — Jun 30, 2025
HCYC Holding Co (CIK 0002006779)
Date: June 30, 2025 · CIK: 0002006779 · Accession: 0001641172-25-017183
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File numbers found in text: 333-282624
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CORRESP
1
filename1.htm
June
30, 2025
VIA
EDGAR
United
States Securities and Exchange Commission
Division
of Corporation Finance
Office
of Finance
100
F Street, NE
Washington,
DC 20549
Re:
HCYC Holding Company
Amendment No. 4 to Registration Statement on Form
F-4
Filed June 13, 2025
File No. 333-282624
Ladies
and Gentlemen:
On
behalf of our client, AlphaTime Acquisition Corp. (“ATMC”) and HCYC Holding Company (“HCYC”), represented
by Celine & Partners, PLLC, we are writing to submit responses to the comments of the staff (the “Staff”) of the
Division of Corporation Finance of the United States Securities and Exchange Commission (the “Commission”) set forth
in its letter, dated June 25, 2025, relating to HCYC’s Amendment No. 4 to Registration Statement on Form F-4 filed June 13, 2025.
HCYC
is filing via EDGAR Amendment No. 5 to Registration Statement on Form F-4, which reflects responses to the comments received by the Staff
and certain updated information.
We
have set forth below the comments in the Staff’s letter, in bold, and the responses thereto.
Amendment
No. 4 to Registration Statement on Form F-4
Summary
of the Proxy Statement/Prospectus
Redemption
Rights, page 47
1.
We note
your response to prior comment 6 and your revised disclosure describing the shareholders’ redemption rights. Please further
expand your discussion to describe the rights of non-redeeming shareholders and the events that permit for redemption, such
as extensions of deadlines to consummate the merger or other events.
Response:
We acknowledge the Staff’s comment and advise the Staff that at the disclosure on page 47 have been revised to address the
Staff’s comment.
Related
Party Transactions, page 151
2.
We note
your response to our prior comment 1. Please update information in this section to include 2024 related party transactions listed
on pages F-69 and F-70 or advise. In addition, disclose that you have included in this section all related party transactions for
the last three fiscal years and up to the most recent date. Finally, identify each related party referenced in this section and explain
how they are a related party.
Response:
We acknowledge the Staff’s comment and advise the Staff that at the disclosure on page 187 has been revised to address the
Staff’s comment.
*
* * * * * *
If
you have any questions, please feel free to contact me at (713) 651-2678. Thank you for your cooperation and prompt attention to this
matter.
Sincerely,
/s/ Michael
J. Blankenship
Michael J. Blankenship