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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

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
October 31, 2024
Author
Office of Technology
Form
UPLOAD
Company
Robot Consulting Co., Ltd.

Letter

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

Show Raw Text
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