Correspondence 0001493152-24-035680 from Diginex Ltd (DGNX)
Diginex Ltd
Date: Sept. 10, 2024 · CIK: 0002010499 · Accession: 0001493152-24-035680
AI Filing Summary & Sentiment
Letter
Via EDGAR Division of Corporation Finance Office of Technology Attention: Matthew Crispino Re: Diginex Ltd Amendment No. 3 to Draft Registration Statement on Form F-1 Submitted August 13, 2024 CIK No. 0002010499
Dear Mr. Crispino and Ms. Woo:
Diginex Limited (the “Company”), is hereby responding to the letter, dated August 30, 2024 (the “Comment Letter”), from the staff (the “Staff”) of the U.S. Securities and Exchange Commission, regarding the Company’s Amendment No. 3 to Draft Registration Statement on Form F-1 (the “DRS”). Concurrently with the submission of this letter, the Company is submitting a Registration Statement on Form F-1 (the “Form F-1”) via EDGAR to the Commission for review in accordance with the procedures of the Commission.
The Company has responded to all of the Staff’s comments by revising the DRS to address the comments, by providing an explanation if the Company has not so revised the DRS, or by providing supplemental information as requested. The Staff’s comments are repeated below in italics and followed by the Company’s response. Terms used but not otherwise defined herein have the meanings set forth in the Form F-1. The changes reflected in the Form F-1 include those made in response to the Staff’s comments as well as other updates.
Confidential Draft Registration Statement Filed on Form F-1 on August 13, 2024
Corporate History
The Restructuring, page 32
1. Please given retroactive effect throughout the document to the stock-split consummated
on July 15, 2024.
Response: The Company respectfully acknowledges the Staff’s comment and has addressed the Staff’s comment by making responsive edits throughout the Form F-1 and by including audited financial statements for Diginex Limited for the years ended March 31, 2024 and March 31, 2023 which give retroactive effect to the restructuring that occurred on July 15, 2024 and the stock split that occurred on July 26, 2024.
Division of Corporation Finance
Office of Technology
September 10, 2024
Page
Please call Andrei Sirabionian at (212) 407-4089 or James Prestiano of Loeb & Loeb LLP at (212) 407-4831 if you have any questions or if would like additional information with respect to any of the foregoing.
Very
truly yours,
/s/
Mark Blick
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filename1.htm
Diginex
Limited
Smart-Space
Fintech 2, Room 3
Unit
401-404 Core C, Cyberport, Telegraph Bay
Hong
Kong
September 10,
2024
Via
EDGAR
Division
of Corporation Finance
Office
of Technology
U.S.
Securities & Exchange Commission
100
F Street, NE
Washington,
D.C. 20549
Attention:
Matthew
Crispino
Jan
Woo
Re:
Diginex
Ltd
Amendment
No. 3 to Draft Registration Statement on Form F-1
Submitted
August 13, 2024
CIK
No. 0002010499
Dear
Mr. Crispino and Ms. Woo:
Diginex Limited (the “Company”), is hereby responding
to the letter, dated August 30, 2024 (the “Comment Letter”), from the staff (the “Staff”)
of the U.S. Securities and Exchange Commission, regarding the Company’s Amendment No. 3 to Draft Registration Statement on Form
F-1 (the “DRS”). Concurrently with the submission of this letter, the Company is submitting a Registration Statement
on Form F-1 (the “Form F-1”) via EDGAR to the Commission for review in accordance with the procedures of the
Commission.
The Company has responded to
all of the Staff’s comments by revising the DRS to address the comments, by providing an explanation if the Company has not so
revised the DRS, or by providing supplemental information as requested. The Staff’s comments are repeated below in italics and
followed by the Company’s response. Terms used but not otherwise defined herein have the meanings set forth in the Form F-1. The
changes reflected in the Form F-1 include those made in response to the Staff’s comments as well as other updates.
Confidential
Draft Registration Statement Filed on Form F-1 on August 13, 2024
Corporate
History
The
Restructuring, page 32
1.
Please given retroactive effect throughout the document to the stock-split consummated
on
July 15, 2024.
Response:
The Company respectfully acknowledges the Staff’s comment and has addressed the Staff’s comment by making responsive edits
throughout the Form F-1 and by including audited financial statements for Diginex Limited for the years ended March 31, 2024 and March
31, 2023 which give retroactive effect to the restructuring that occurred on July 15, 2024 and the stock split that occurred on July
26, 2024.
Division
of Corporation Finance
Office
of Technology
September
10, 2024
Page
2
Please
call Andrei Sirabionian at (212) 407-4089 or James Prestiano of Loeb & Loeb LLP at (212) 407-4831 if you have any questions or if
would like additional information with respect to any of the foregoing.
Very
truly yours,
/s/
Mark Blick
Name:
Mark
Blick
Title:
Chief
Executive Officer