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Correspondence 0001641172-25-000734 from Robot Consulting Co., Ltd. (LAWR)

Robot Consulting Co., Ltd.
Date: March 26, 2025 · CIK: 0002007599 · Accession: 0001641172-25-000734

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File numbers found in text: 333-284875

Referenced dates: March 25, 2025

Date
March 19, 2025
Author
Amit Takur
Form
CORRESP
Company
Robot Consulting Co., Ltd.

Letter

Robot Consulting Co., Ltd.

March 26, 2025

Via EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

Attention:

Robert Littlepage

Mariam Mansaray

Mitchell Austin

Re: Robot Consulting Co., Ltd.

Amendment No. 1 to Registration Statement on Form F-1

Filed March 19, 2025

File No. 333-284875

Ladies and Gentlemen:

This letter is in response to the letter dated March 25, 2025, from the staff (the "Staff") of the U.S. Securities and Exchange Commission (the "Commission") addressed to Robot Consulting Co., Ltd. (the "Company," "we," "us," and "our"). For ease of reference, we have recited the Commission's comments in this response and numbered them accordingly. An Amendment No. 2 to Registration Statement on Form F-1 (the "Amended Registration Statement") is being filed to accompany this letter.

Amendment No. 1 to Registration Statement on Form F-1

Management, page 66

1. We note your disclosure on pages 68 and 69 where you state that your board consists of eight directors. However, in your management section on page 66 you only identify six directors. Please revise to reconcile this discrepancy or advise. Additionally, the signature section on page II-5 provides the signature of four directors. Instruction 1 to Signatures of Form F-1 requires a registration statement be signed by at least a majority of the board of directors or persons performing similar functions. Ensure at least a majority of the board of directors signs the registration statement.

Response: In response to the Staff's comment, we have revised the disclosure on pages 68 and 69 of the Amended Registration Statement to clarify that the Company's board of directors consists of six directors. We also confirm that at least a majority of the board of directors has signed the registration statement.

We appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2206.

Very
truly yours,
/s/
Amit Takur

Show Raw Text
CORRESP
 1
 filename1.htm

 Robot Consulting Co., Ltd.

 March
26, 2025

 Via EDGAR

 Division of Corporation Finance

 Office of Technology

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C., 20549

 Attention:

 Robert
 Littlepage

 Mariam
 Mansaray

 Mitchell
 Austin

 Re:
 Robot
 Consulting Co., Ltd.

 Amendment No. 1 to
 Registration Statement on Form F-1

 Filed
 March 19, 2025

 File
 No. 333-284875

 Ladies
and Gentlemen:

 This
letter is in response to the letter dated March 25, 2025, from the staff (the "Staff") of the U.S. Securities and
Exchange Commission (the "Commission") addressed to Robot Consulting Co., Ltd. (the "Company," "we,"
"us," and "our"). For ease of reference, we have recited the Commission's comments in this response and
numbered them accordingly. An Amendment No. 2 to Registration Statement on Form F-1 (the "Amended Registration Statement")
is being filed to accompany this letter.

 Amendment
No. 1 to Registration Statement on Form F-1

 Management,
page 66

 1.
We note your disclosure on pages 68 and 69 where you state that your board consists of eight directors. However, in your management section
on page 66 you only identify six directors. Please
revise to reconcile this discrepancy or advise. Additionally, the signature section on page II-5 provides the signature
of four directors. Instruction 1 to Signatures of Form F-1 requires a registration statement be signed by at least a majority of
the board of directors or persons performing similar functions. Ensure at least a majority of the board of directors signs the registration
statement.

 Response:
 In response to the Staff's comment, we have revised the disclosure on pages 68 and 69 of the Amended Registration Statement
to clarify that the Company's board of directors consists of six directors. We also confirm that at least a majority
of the board of directors has signed the registration statement.

 We
appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel,
Ying Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2206.

 Very
truly yours,

 /s/
 Amit Takur

 Name:
 Amit Takur

 Title:
 Chief Executive Officer
 and Director

 cc:
 Ying Li, Esq.

 Hunter
 Taubman Fischer & Li LLC