SEC Comment Letter for VISTEK LTD (VTEK) (CIK 0002013100) — Apr 1, 2025
VISTEK LTD (VTEK) (CIK 0002013100)
Date: April 1, 2025 · CIK: 0002013100 · Accession: 0000000000-25-003504
AI Filing Summary & Sentiment
File numbers found in text: 333-284559
Letter
April 1, 2025 Teck Hong Ho Chief Executive Officer Vistek Limited 39 Woodlands Close #08-11 Mega@Woodlands Singapore 737856 Re:Vistek Limited Amendment No. 2 to Registration Statement on Form F-1 Filed March 21, 2025 File No. 333-284559 Dear Teck Hong Ho: We have reviewed your amended registration statement and have the following comment. 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. 2 to Registration Statement on Form F-1 Signatures, page II-6 1.We refer to your revised exhibits 10.4 through 10.6, and note that these exhibits are dated February 26, 2025. Given that the agreements state that they are effective as of such date, and it appears that these directors have been already appointed as directors, please revise your signature page to include these directors' signatures. In addition, please reconcile your disclosures elsewhere in the registration statement indicating that the director nominees will only begin serving upon the effectiveness of the registration statement, or advise.
April 1, 2025 Page 2 Please contact Howard Efron at 202-551-3439 or Jennifer Monick at 202-551-3295 if you have questions regarding comments on the financial statements and related matters. Please contact Benjamin Holt at 202-551-6614 or Dorrie Yale at 202-551-8776 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc:Yuning “Grace” Bai, Esq.
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April 1, 2025
Teck Hong Ho
Chief Executive Officer
Vistek Limited
39 Woodlands Close #08-11
Mega@Woodlands
Singapore 737856
Re:Vistek Limited
Amendment No. 2 to Registration Statement on Form F-1
Filed March 21, 2025
File No. 333-284559
Dear Teck Hong Ho:
We have reviewed your amended registration statement and have the following
comment.
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. 2 to Registration Statement on Form F-1
Signatures, page II-6
1.We refer to your revised exhibits 10.4 through 10.6, and note that these exhibits are
dated February 26, 2025. Given that the agreements state that they are effective as of
such date, and it appears that these directors have been already appointed as directors,
please revise your signature page to include these directors' signatures. In addition,
please reconcile your disclosures elsewhere in the registration statement indicating
that the director nominees will only begin serving upon the effectiveness of the
registration statement, or advise.
April 1, 2025
Page 2
Please contact Howard Efron at 202-551-3439 or Jennifer Monick at 202-551-3295 if
you have questions regarding comments on the financial statements and related matters.
Please contact Benjamin Holt at 202-551-6614 or Dorrie Yale at 202-551-8776 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Yuning “Grace” Bai, Esq.