Correspondence 0001493152-25-008172 from Zenta Group Co Ltd (ZGM)
Zenta Group Co Ltd
Date: Feb. 25, 2025 · CIK: 0002011458 · Accession: 0001493152-25-008172
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-284140
Referenced dates: February 20, 2024
Letter
Via Edgar Transmission Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services Amendment No. 1 to Registration Statement on Form F-1 Filed February 7, 2025 File No. 333-284140
Re: Zenta Group Co Ltd
Dear Ms. Hough / Mr. Jaskot:
As counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated February 20, 2024 from the Securities and Exchange Commission (the “Commission”) in which the staff of the Commission (the “Staff”) commented on the above-referenced Draft Registration Statement on Form F-1 (the “Form F-1”).
For the Staff’s convenience, the Staff’s comment has been stated below in its entirety, with the Company’s response set out immediately underneath such comment.
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.
Response: We respectfully advise the Staff that we have updated the disclosure in industry overview to provide statistics on how the Chinese and Macau property market were under pressure on page 59, and have amended the disclosures on pages 1, 24 and 64 to refer to cross reference to the industry overview page. We have also revised the disclosure to the risk factor on page 24 to discuss the market under pressure, as well as discussed Trend Information on page 52.
* * *
Please contact the undersigned at (852) 3923-1188 if you have any questions with respect to the responses contained in this letter.
Sincerely,
/s/
Lawrence S. Venick
Show Raw Text
CORRESP
1
filename1.htm
February
25, 2025
Via
Edgar Transmission
Ms.
Jenna Hough / Mr. Erin Jaskot
Securities
and Exchange Commission
Division
of Corporation Finance
Office
of Trade & Services
Washington,
D.C. 20549
Re:
Zenta
Group Co Ltd
Amendment
No. 1 to Registration Statement on Form F-1
Filed
February 7, 2025
File
No. 333-284140
Dear
Ms. Hough / Mr. Jaskot:
As
counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated February 20, 2024 from the
Securities and Exchange Commission (the “Commission”) in which the staff of the Commission (the “Staff”)
commented on the above-referenced Draft Registration Statement on Form F-1 (the “Form F-1”).
For
the Staff’s convenience, the Staff’s comment has been stated below in its entirety, with the Company’s response set
out immediately underneath such comment.
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.
Response:
We respectfully advise the Staff that we have updated the disclosure in industry overview to provide statistics on how the Chinese
and Macau property market were under pressure on page 59, and have amended the disclosures on pages 1, 24 and 64 to refer to cross reference
to the industry overview page. We have also revised the disclosure to the risk factor on page 24 to discuss the market under pressure,
as well as discussed Trend Information on page 52.
*
* *
Please
contact the undersigned at (852) 3923-1188 if you have any questions with respect to the responses contained in this letter.
Sincerely,
/s/
Lawrence S. Venick
Lawrence
S. Venick
Direct
Dial: +852.3923.1188
Email:
lvenick@loeb.com