SEC Comment Letter 0000000000-24-009649 to 707 Cayman Holdings Ltd. (JEM)
707 Cayman Holdings Ltd.
Date: Aug. 23, 2024 · CIK: 0002018222 · Accession: 0000000000-24-009649
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Letter
August 23, 2024 Elvis Cheung Chief Executive Officer 707 Cayman Holdings Ltd. 5/F., AIA Financial Centre 712 Prince Edward Road East San Po Kong, Kowloon, Hong Kong Re:707 Cayman Holdings Ltd. Amendment No. 3 to Draft Registration Statement on Form F-1 Submitted August 5, 2024 CIK No. 0002018222 Dear Elvis Cheung: We have reviewed your amended draft registration statement and have the following comment(s). 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 July 31, 2024 letter. Draft Registration Statement submitted August 5, 2024 General 1.We note your revised disclosure pursuant to comment 2 and reissue in part. Please revise the resale prospectus cover page to discuss your status as a controlled company. Please contact Amy Geddes at 202-551-3304 or Angela Lumley at 202-551-3398 if you have questions regarding comments on the financial statements and related matters. Please contact Jenna Hough at 202-551-3063 or Lilyanna Peyser at 202-551-3222 with any other questions.
August 23, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Trade & Services cc:David L. Ficksman
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August 23, 2024
Elvis Cheung
Chief Executive Officer
707 Cayman Holdings Ltd.
5/F., AIA Financial Centre
712 Prince Edward Road East
San Po Kong, Kowloon, Hong Kong
Re:707 Cayman Holdings Ltd.
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted August 5, 2024
CIK No. 0002018222
Dear Elvis Cheung:
We have reviewed your amended draft registration statement and have the following
comment(s).
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
July 31, 2024 letter.
Draft Registration Statement submitted August 5, 2024
General
1.We note your revised disclosure pursuant to comment 2 and reissue in part. Please revise
the resale prospectus cover page to discuss your status as a controlled company.
Please contact Amy Geddes at 202-551-3304 or Angela Lumley at 202-551-3398 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jenna Hough at 202-551-3063 or Lilyanna Peyser at 202-551-3222 with any other
questions.
August 23, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:David L. Ficksman