SEC Comment Letter 0000000000-25-002008 to Zenta Group Co Ltd (ZGM)
Zenta Group Co Ltd
Date: Feb. 20, 2025 · CIK: 0002011458 · Accession: 0000000000-25-002008
AI Filing Summary & Sentiment
File numbers found in text: 333-284140
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February 20, 2025
Ng Wai Ian
Director, Chairman of the Board and Chief Executive Officer
Zenta Group Co Ltd
Avenida do Infante D. Henrique
No. 47-53A, Macau Square
8th Floor, Unit J
Macau 999078
Re:Zenta Group Co Ltd
Amendment No. 1 to Registration Statement on Form F-1
Filed February 7, 2025
File No. 333-284140
Dear Ng Wai Ian:
We have reviewed your amended registration statement and have the following
comment(s).
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. Unless we note
otherwise, any references to prior comments are to comments in our January 31, 2025 letter.
Amendment No. 1 to Form F-1 filed February 7, 2025
Prospectus Summary
Overview, page 1
1.We note your revised disclosure pursuant to prior comment 5. Here and elsewhere as
applicable, such as on page 64, please explain what you mean by the property markets
are "under pressure" in Mainland China and Macau and how and why that impacted
your industrial park consultation services. To the extent this represents a known trend
or uncertainty that is reasonably likely to have a material impact on future operating
results, please disclose this in an appropriate place in your registration statement. See
Item 5.D. of Form 20-F.
February 20, 2025
Page 2
Please contact Nasreen Mohammed at 202-551-3773 or Adam Phippen at 202-551-
3336 if you have questions regarding comments on the financial statements and related
matters. Please contact Jenna Hough at 202-551-3063 or Erin Jaskot at 202-551-3442 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Lawrence Venick