SEC Company Response from VISTEK LTD (VTEK) (CIK 0002013100) — May 5, 2025
VISTEK LTD (VTEK) (CIK 0002013100)
Date: May 5, 2025 · CIK: 0002013100 · Accession: 0001641172-25-008707
AI Filing Summary & Sentiment
File numbers found in text: 333-284559
Referenced dates: May 5, 2025
Letter
Division of Corporation Finance Office of Real Estate & Construction Re: Vistek Limited Amendment No. 5 to Registration Statement on Form F-1 Filed May 1, 2025 File No. 333-284559
Dear Mr. Efron:
This letter is in response to the letter dated May 5, 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. 5 to Registration Statement on Form F-1
Exhibits
1. We acknowledge your counsel’s revised opinion filed as Exhibit 5.1. We note that the revised opinion has deleted Schedule 1, which is referenced by counsel’s opinion. Please re-file the opinion to include the deleted Schedule
RESPONSE: We note the Staff’s comment and respectfully advise the Staff that we have revised and refiled Exhibit 5.1 to include the omitted Schedule 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
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filename1.htm
Vistek
Limited
39
Woodlands Close #08-11
Mega@Woodlands
Singapore
737856
May
5, 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. 5 to Registration Statement on Form F-1
Filed
May 1, 2025
File
No. 333-284559
Dear
Mr. Efron:
This
letter is in response to the letter dated May 5, 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. 5 to Registration Statement on Form F-1
Exhibits
1.
We
acknowledge your counsel’s revised opinion filed as Exhibit 5.1. We note that the revised opinion has deleted Schedule 1, which is
referenced by counsel’s opinion. Please re-file the opinion to include the deleted Schedule
RESPONSE:
We note the Staff’s comment and respectfully advise the Staff that we have revised and refiled Exhibit 5.1 to include the omitted
Schedule 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