Correspondence 0001493152-24-038975 from Eastern International Ltd. (ELOG)
Eastern International Ltd.
Date: Oct. 1, 2024 · CIK: 0002013320 · Accession: 0001493152-24-038975
AI Filing Summary & Sentiment
File numbers found in text: 333-281900
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CORRESP
1
filename1.htm
Direct
Phone: 703.618.2503
jeffrey.li@fisherBroyles.com
October
1, 2024
U.S.
Securities and Exchange Commission
Division
of Corporation Finance
Office
of Energy & Transportation
100
F Street, N.E.
Washington,
D.C. 20549
Attn:
Myra
Moosariparambil
Shannon
Buskirk
Michael
Purcell
Liz
Packebusch
Re:
Eastern
International Ltd.
Registration
Statement on Form F-1
Filed
September 3, 2024
File
No. 333-281900
Ladies
and Gentlemen:
On
behalf of our client, Eastern International Ltd, a foreign private issuer organized under the laws of Cayman Islands (the “Company”,
“We” or “Our”), we are submitting this letter and the following information in response to a letter,
dated September 11, 2024, from the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) with respect to the Company’s Registration Statement on Form F-1 (the “Registration
Statement”) filed with the Commission on September 3, 2024. Concurrently with the submission of this letter, the Company
is filing herewith its Amendment No.1 to the registration statement on Form F-1 (the “Amended Registration Statement”)
and certain exhibits via EDGAR to the Commission.
To
facilitate your review, we have separately delivered to you a courtesy copy of the Amended Registration Statement, marked to show changes
to the Registration Statement filed with the Commission on September 3, 2024.
The
Staff’s comments are repeated below in bold and are followed by the Company’s responses. We have included page references
in the Registration Statement where the language addressing a particular comment appears. Capitalized terms used in this letter but otherwise
not defined herein shall have the meanings ascribed to such terms in the Registration Statement.
In
addition to revising the disclosure in response to the Staff’s comments, the Company has also included other information and data
to reflect recent developments.
Registration
Statement on Form F-1 Principal Shareholders, page 101
1.
Please
revise your ownership table to include the total aggregate ownership of each shareholder.
Response:
We have revised our ownership table to include the total aggregate voting power of each shareholder on page 101.
Exhibits
2.
We
note your Memorandum and Articles of Association filed as Exhibit 3.1 provide that unless the directors otherwise prescribe, the
financial year of the Company shall end on 31 December in each year. However, you disclose in your prospectus that your fiscal year
end is March 31. Please advise or revise.
Response:
We have filed the Second Amended and Restated Memorandum and Articles of Association as
Exhibit 3.1 which provides that the financial year of the Company shall end on March 31 in each year.
We
thank the Staff for its review of the foregoing and the Registration Statement. If you have further comments, please feel free to contact
me at Jeffrey.li@fisherbroyles.com or by telephone at (703) 618-2503.
Very
truly yours,
/s/
Jeffrey Li
Jeffrey
Li
Enclosures
cc:
Albert
Wong, Chief Executive Officer of Eastern International Ltd.