SEC Comment Letter for AMBITIONS ENTERPRISE MANAGEMENT CO. L.L.C (AHMA) (CIK 0002010959) (AHMA) — Mar 27, 2025
AMBITIONS ENTERPRISE MANAGEMENT CO. L.L.C (AHMA) (CIK 0002010959)
Date: March 27, 2025 · CIK: 0002010959 · Accession: 0000000000-25-003299
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File numbers found in text: 333-284789
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March 27, 2025
Zhengang Tang
Chief Executive Officer
Ambitions Enterprise Management Co. L.L.C.
630 Business Village Block B
Port Saeed Deira, Dubai
United Arab Emirates
Re:Ambitions Enterprise Management Co. L.L.C.
Amendment No. 1 to Registration Statement on Form F-1
Filed March 18, 2025
File No. 333-284789
Dear Zhengang Tang:
We have reviewed your registration statement and have the following comments.
Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Amendment No. 1 to Registration Statement on Form F-1
Related Party Transactions, page 82
1.We note that the information in this section is dated and should be revised to provide
the required information as of and "up to the date of the document." Please update and
revise as applicable. Refer to Item 7.B of Form 20-F. In this regard, we note that the
included charts use reference dates of June 30, 2024 and December 31, 2023, 2022,
and 2021. Please revise to include a column for December 31, 2024 (or a more recent
date, if available).
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
March 27, 2025
Page 2
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact James Giugliano at 202-551-3319 or Joel Parker at 202-551-3651 if
you have questions regarding comments on the financial statements and related
matters. Please contact Scott Anderegg at 202-551-3342 or Donald Field at 202-551-3680
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services