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
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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