Correspondence 0001213900-24-074918 from Powell Max Ltd (PMAX)
Powell Max Ltd
Date: Sept. 3, 2024 · CIK: 0002012096 · Accession: 0001213900-24-074918
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File numbers found in text: 333-279859
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CORRESP
1
filename1.htm
VIA EDGAR
September 3, 2024
U.S. Securities and Exchange Commission
Division of Corporate Finance
Office of Trade and Services
100 F Street, N.E.
Washington, DC 20549
Attention:
Blaise Rhodes
Doug Jones
Brian Fetterolf
Erin Jaskot
Re:
Powell Max Limited
File No. 333-279859
Registration Statement on Form F-1 as amended
Ladies and Gentlemen:
Pursuant to Rule 461 of the
General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, WallachBeth
Capital LLC, as representative of the underwriters, hereby requests acceleration of the effective date of the above-referenced Registration
Statement so that it will become effective at 4:00 p.m., Eastern Time, on September 4, 2024, or as soon thereafter as practicable.
Pursuant to Rule 460 under
the Act, we wish to advise you that the underwriters have distributed as many copies of the preliminary prospectus dated July 30, 2024,
to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution of the preliminary prospectus.
The undersigned confirms
that it has complied with and will continue to comply with, and it has been informed or will be informed by participating dealers that
they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection
with the above-referenced issue.
Very truly yours,
WallachBeth Capital LLC
By:
/s/ Eric Schweitzer
Name:
Eric Schweitzer
Title:
Chief Compliance Officer