SEC Company Response from VISTEK LTD (VTEK) (CIK 0002013100) — Apr 28, 2025
VISTEK LTD (VTEK) (CIK 0002013100)
Date: April 28, 2025 · CIK: 0002013100 · Accession: 0001641172-25-006405
AI Filing Summary & Sentiment
File numbers found in text: 333-284559
Referenced dates: April 22, 2025
Letter
Division of Corporation Finance Office of Real Estate & Construction Vistek Limited Amendment No. 3 to Registration Statement on Form F-1 Filed April 15, 2025 File No. 333-284559
Dear Mr. Efron:
This letter is in response to the letter dated April 22, 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. 3 to Registration Statement on Form F-1
Exhibits
1. Please have counsel revise the legal opinion filed as Exhibit 5.1 to also provide an opinion regarding the shares offered by the Selling Shareholders and the Resale Shareholders. In this regard, we note that the opinion defines the “Shares” as those shares being offered and sold “to the public by the Company.” Refer to Section II.B.2.h of Staff Legal Bulletin No. 19.
RESPONSE: We note the Staff’s comment and respectfully advise the Staff that we have revised and refiled Exhibit 5.1 to opine on the shares being offered by the selling shareholders of the Company and the resale shareholders of the Company.
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
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filename1.htm
Vistek Limited
39 Woodlands Close #08-11
Mega@Woodlands
Singapore 737856
April 28, 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. 3 to Registration Statement on Form
F-1
Filed April 15, 2025
File No. 333-284559
Dear Mr. Efron:
This
letter is in response to the letter dated April 22, 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. 3 to Registration Statement on Form F-1
Exhibits
1.
Please
have counsel revise the legal opinion filed as Exhibit 5.1 to also provide an opinion regarding the shares offered by the Selling
Shareholders and the Resale Shareholders. In this regard, we note that the opinion defines the “Shares” as those shares
being offered and sold “to the public by the Company.” Refer to Section II.B.2.h of Staff Legal Bulletin No. 19.
RESPONSE:
We note the Staff’s comment and respectfully advise the Staff that we have revised and refiled Exhibit 5.1 to opine on the
shares being offered by the selling shareholders of the Company and the resale shareholders of the Company.
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