SEC Company Response from VISTEK LTD (VTEK) (CIK 0002013100) — Apr 15, 2025
VISTEK LTD (VTEK) (CIK 0002013100)
Date: April 15, 2025 · CIK: 0002013100 · Accession: 0001641172-25-004891
AI Filing Summary & Sentiment
File numbers found in text: 333-284559
Referenced dates: April 1, 2025
Letter
Division of Corporation Finance Office of Real Estate & Construction Re: Vistek Limited Amendment No. 2 to Registration Statement on Form F-1 Filed March 21, 2025 File No. 333-284559
Dear Mr. Efron:
This letter is in response to the letter dated April 1, 2025, from the staff (the “Staff”) of the U.S. Securities Exchange Commission (“SEC”) addressed to Vistek Limited (the “Company,” “we,” and “our”). For ease of reference, we have recited SEC’s comments in this response and numbered them accordingly. An amended registration statement on Form F-1 (the “Registration Statement Amendment”) is being submitted to accompany this letter.
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.
RESPONSE: We note the Staff’s comment and respectfully advise the Staff that we have revised and refiled Exhibits 10.4 to 10.6 which reflect the director nominees of the Company will begin serving in their capacities as directors upon the effectiveness of the Registration Statement on Form F-1.
We hope this response has addressed all of the Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein, please contact our securities counsel William S. Rosenstadt, Esq., or Jason Ye, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal, or jye@orllp.legal.
Vistek Limited
/s/ Teck Hong Ho
Name: Teck Hong Ho
Title: Chief Executive Officer
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CORRESP
1
filename1.htm
Vistek
Limited
39
Woodlands Close #08-11
Mega@Woodlands
Singapore
737856
April
15, 2025
Via
Electronic Mail
Division
of Corporation Finance
Office
of Real Estate & Construction
U.S.
Securities Exchange Commission
Attn:
Mr. Howard Efron
Re:
Vistek
Limited
Amendment
No. 2 to Registration Statement on Form F-1
Filed
March 21, 2025
File
No. 333-284559
Dear
Mr. Efron:
This
letter is in response to the letter dated April 1, 2025, from the staff (the “Staff”) of the U.S. Securities Exchange Commission
(“SEC”) addressed to Vistek Limited (the “Company,” “we,” and “our”). For ease of reference,
we have recited SEC’s comments in this response and numbered them accordingly. An amended registration statement on Form F-1 (the
“Registration Statement Amendment”) is being submitted to accompany this letter.
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.
RESPONSE:
We note the Staff’s comment and respectfully advise the Staff that we have revised and refiled Exhibits 10.4 to 10.6 which
reflect the director nominees of the Company will begin serving in their capacities as directors upon the effectiveness of the Registration
Statement on Form F-1.
We
hope this response has addressed all of the Staff’s concerns relating to the comment letter. Should you have additional questions
regarding the information contained herein, please contact our securities counsel William S. Rosenstadt, Esq., or Jason Ye, Esq. of Ortoli
Rosenstadt LLP at wsr@orllp.legal, or jye@orllp.legal.
Vistek Limited
/s/
Teck Hong Ho
Name:
Teck Hong Ho
Title:
Chief Executive Officer