SecProbe.io

Filing text and metadata
Intelligence Terminal Search Topics Monthly Activity About

Correspondence 0001493152-25-006754 from Eastern International Ltd. (ELOG)

Eastern International Ltd.
Date: Feb. 14, 2025 · CIK: 0002013320 · Accession: 0001493152-25-006754

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 333-281900

Date
Feb. 14, 2025
Author
Jeffrey Li
Form
CORRESP
Company
Eastern International Ltd.

Letter

Direct Phone: 703.618.2503

jeffrey.li@fisherBroyles.com

February 14, 2025

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

F Street, N.E.

Washington, D.C. 20549

Attn: Myra Moosariparambil

Shannon Buskirk

Liz Packebusch

Re: Eastern International Ltd.

Amendment No. 3 to Registration Statement on Form F-1

Filed January 21, 2025

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 January 27, 2025, 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, amended on October 1, 2024, December 31, 2024 and January 21, 2025. Concurrently with the submission of this letter, the Company is filing herewith its Amendment No.4 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 January 21, 2025.

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.

Amendment No. 2 to Registration Statement on Form F-1

Index to Consolidated Financial Statements

Notes to Unaudited Interim Condensed Consolidated Financial Statements

Note 13 - Segment reporting, page F-29

1. We note your response to comment 1. You revised the disclosure to state gross profit is the profitability measure used by the CODM in making decision about allocating resources and assessing performances. Please address the following:

● In your revised disclosure, you continue to present segment profit for each segment. Please revise to remove this measure for each segment, or explain why you believe the presentation is appropriate and in accordance with ASC 280-10-50.

● In the table titled “Other segment disclosures” on page F-30, you include amounts for the six months ended September 30, 2023. However, you have included the segment assets balance as of March 31, 2024. Please revise to include the segment assets balance as of September 30, 2023.

● Please revise the segment footnote for the fiscal years ended March 31, 2024 and March 31, 2023 on page F-66 to conform to the changes in your segment reporting footnote for the six months ended September 30, 2024.

Response: We acknowledge the Staff’s comments and made the following revisions to the financial statements:

On page F-29 and F-30, we revised our disclosure in segment reporting to remove the “segment profit” measure since it’s not the profitability measure used by our CODM in making decisions.

On page F-30, we revised our disclosure in “Other segment disclosures” to include segment assets balance as of September 30, 2023.

On pages F-65 and F-66, we revised the segment footnote for the fiscal years ended March 31, 2024 and 2023 to conform with the changes in our segment reporting footnote for the six months ended September 30, 2024.

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

Show Raw Text
CORRESP
1
filename1.htm

    Direct
    Phone: 703.618.2503

    jeffrey.li@fisherBroyles.com

February
14, 2025

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

    Liz
    Packebusch

    Re:
    Eastern
    International Ltd.

    Amendment
    No. 3 to Registration Statement on Form F-1

    Filed
    January 21, 2025

    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 January 27, 2025, 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, amended on October 1, 2024, December 31, 2024 and January 21, 2025. Concurrently with the submission
of this letter, the Company is filing herewith its Amendment No.4 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 January 21, 2025.

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.

Amendment
No. 2 to Registration Statement on Form F-1

Index
to Consolidated Financial Statements

Notes
to Unaudited Interim Condensed Consolidated Financial Statements

Note
13 - Segment reporting, page F-29

    1.
    We
    note your response to comment 1. You revised the disclosure to state gross profit is the profitability measure used by the CODM in
    making decision about allocating resources and assessing performances. Please address the following:

    ●
    In your revised disclosure, you continue to present segment profit for each segment. Please revise to remove this measure for each
    segment, or explain why you believe the presentation is appropriate and in accordance with ASC 280-10-50.

    ● In
    the table titled “Other segment disclosures” on page F-30, you include amounts for the six months ended September 30,
    2023. However, you have included the segment assets balance as of March 31, 2024. Please revise to include the segment assets
    balance as of September 30, 2023.

    ● Please
    revise the segment footnote for the fiscal years ended March 31, 2024 and March 31, 2023 on page F-66 to conform to the changes in
    your segment reporting footnote for the six months ended September 30, 2024.

Response:
We acknowledge the Staff’s comments and made the following revisions to the financial statements:

On
page F-29 and F-30, we revised our disclosure in segment reporting to remove the “segment profit” measure since it’s
not the profitability measure used by our CODM in making decisions.

On
page F-30, we revised our disclosure in “Other segment disclosures” to include segment assets balance as of September 30,
2023.

On
pages F-65 and F-66, we revised the segment footnote for the fiscal years ended March 31, 2024 and 2023 to conform with the changes in
our segment reporting footnote for the six months ended September 30, 2024.

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.

    2