SEC Comment Letter 0000000000-24-006953 to PTL Ltd (PTLE)
PTL Ltd
Date: June 17, 2024 · CIK: 0002016337 · Accession: 0000000000-24-006953
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United States securities and exchange commission logo
June 17, 2024
Ying Ying Chow
Chief Executive Officer
PTL Limited
111 North Bridge Road
#23-06A
Peninsula Plaza
Singapore 179098
Re:PTL Limited
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted on June 4, 2024
CIK No. 0002016337
Dear Ying Ying Chow:
We have reviewed your amended draft registration statement and have the following
comment.
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
May 23, 2024 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 61
1.Refer to your revised disclosure in response to prior comment 2. You twice mention
therein "when the sales volume reaches a certain level." Please disclose what that sales
volume level is and why that level is determinative.
FirstName LastNameYing Ying Chow
Comapany NamePTL Limited
June 17, 2024 Page 2
FirstName LastName
Ying Ying Chow
PTL Limited
June 17, 2024
Page 2
Please contact Aamira Chaudhry at 202-551-3389 or Doug Jones at 202-551-3309 if you
have questions regarding comments on the financial statements and related matters. Please
contact Joshua Gorsky at 202-551-7836 or Suzanne Hayes at 202-551-3675 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Mengyi “Jason” Ye, Esq.