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SEC Comment Letter 0000000000-25-001571 to 707 Cayman Holdings Ltd. (JEM)

707 Cayman Holdings Ltd.
Date: Feb. 12, 2025 · CIK: 0002018222 · Accession: 0000000000-25-001571

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File numbers found in text: 333-281949

Date
February 12, 2025
Author
Elvis Cheung
Form
UPLOAD
Company
707 Cayman Holdings Ltd.

Letter

February 12, 2025 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. 2 to Registration Statement on Form F-1 Filed January 23, 2025 File No. 333-281949 Dear Elvis Cheung: We have reviewed your amended registration statement and have the following comment(s). Please respond to this letter by amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our January 15, 2025 letter. Amendment No. 2 to Form F-1 filed January 23, 2025 Summary Financial Data Balance Sheet Data, page 10 1.Please review the headers in the table here to ensure the proper fiscal years are identified. Specifically, it appears some of the columns labeled "2023" should be labeled "2024."

February 12, 2025 Page 2 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. Sincerely, Division of Corporation Finance Office of Trade & Services cc:David L. Ficksman

Show Raw Text
February 12, 2025
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. 2 to Registration Statement on Form F-1
Filed January 23, 2025
File No. 333-281949
Dear Elvis Cheung:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our January 15, 2025 letter.
Amendment No. 2 to Form F-1 filed January 23, 2025
Summary Financial Data
Balance Sheet Data, page 10
1.Please review the headers in the table here to ensure the proper fiscal years are
identified. Specifically, it appears some of the columns labeled "2023" should be
labeled "2024."

February 12, 2025
Page 2
            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.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:David L. Ficksman