Correspondence 0001213900-24-109271 from Powell Max Ltd (PMAX)
Powell Max Ltd
Date: Dec. 16, 2024 · CIK: 0002012096 · Accession: 0001213900-24-109271
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Reasoning
File numbers found in text: 333-283547
Letter
Powell Max Limited
22/F., Euro Trade Centre,
13-14 Connaught Road Central,
Hong Kong
December 16, 2024
VIA EDGAR
Division of Corporation Finance
Office of Trade & Services
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention: Rebekah Reed
Re: Powell Max Limited (the “Company”) (CIK No. 0002012096)
Registration Statement on Form F-1, as amended
File No. 333-283547
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, the Company hereby requests acceleration of effectiveness of the above referenced Registration Statement so that it will become effective at 4:00 pm EST on December 19, 2024, or as soon as thereafter practicable. The Company acknowledges that (i) should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing, (ii) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing, and (iii) the Company may not assert staff comments or the declaration of effectiveness as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
The Company hereby authorizes Clayton Parker of K&L Gates LLP to orally modify or withdraw this request for acceleration.
Very truly yours,
Powell Max Limited
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Powell Max Limited
22/F., Euro Trade Centre,
13-14 Connaught Road Central,
Hong Kong
December
16, 2024
VIA EDGAR
Division of Corporation Finance
Office of Trade & Services
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention: Rebekah Reed
Re: Powell Max Limited (the “Company”) (CIK No.
0002012096)
Registration Statement on Form F-1, as amended
File No. 333-283547
Ladies and Gentlemen:
Pursuant to Rule 461
under the Securities Act of 1933, as amended, the Company hereby requests acceleration of effectiveness of the above referenced
Registration Statement so that it will become effective at 4:00 pm EST on December 19, 2024, or as soon as thereafter practicable.
The Company acknowledges that (i) should the Securities and Exchange Commission (the “Commission”) or the staff, acting
pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with
respect to the filing, (ii) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the
filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the
filing, and (iii) the Company may not assert staff comments or the declaration of effectiveness as defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the United States.
The Company hereby authorizes Clayton Parker of K&L Gates LLP to orally modify
or withdraw this request for acceleration.
Very truly yours,
Powell Max Limited
By:
/s/ Tsz Kin Wong
Name:
Tsz Kin Wong
Title:
CEO and Executive Director