SEC Comment Letter 0000000000-24-012156 to Robot Consulting Co., Ltd. (LAWR)
Robot Consulting Co., Ltd.
Date: Oct. 31, 2024 · CIK: 0002007599 · Accession: 0000000000-24-012156
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October 31, 2024
Amit Takur
Chief Executive Officer
Robot Consulting Co., Ltd.
Le Graciel Building 2, 6th Floor
5-22-6 Shinbashi, Minato Ward
Tokyo, 105-0005, Japan
Re:Robot Consulting Co., Ltd.
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted October 18, 2024
CIK No. 0002007599
Dear Amit Takur:
We have reviewed your amended draft registration statement and have the following
comments.
Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. 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 the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 3 to Draft Registration Statement on Form F-1
Financial Statements
Note 20. Subsequent Events, page F-19
1.Refer to the ShareWis purchase in June 2024 disclosed on page 55. If material, please
expand the subsequent events disclosure to include a description of this purchase,
including the amount of the purchase and the terms of the agreement.
October 31, 2024
Page 2
Exhibits
2.On page 55, you discuss your agreement with ShareWis Co., Ltd.
Please file the agreement with ShareWis or tell us why you believe this is not
required. Consider Item 601(b)(10) of Regulation S-K.
Please contact Claire DeLabar at 202-551-3349 or Robert Littlepage at 202-551-3361
if you have questions regarding comments on the financial statements and related
matters. Please contact Mariam Mansaray at 202-551-6356 or Mitchell Austin at 202-551-
3574 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Yung Li