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CORRESP Filing

707 Cayman Holdings Ltd.
Date: June 5, 2025 · CIK: 0002018222 · Accession: 0001641172-25-013731

Offering / Registration Process

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File numbers found in text: 333-281949

Date
June 5, 2025
Author
Bancroft Capital, LLC
Form
CORRESP
Company
707 Cayman Holdings Ltd.

Letter

June 5, 2025

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

F Street, N.E.

Washington, D.C. 20549

Attention:

Mara Ransom

Lilyanna Peyser

Division of Corporate Finance

Re: 707 Cayman Holdings Limited

Registration Statement on Form F-1, as amended (File No. 333-281949)

Request for Acceleration of Effectiveness

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the "Securities Act"), we, the underwriter (the "Underwriter"), hereby join in the request of 707 Cayman Holdings Limited (the "Registrant"), for the acceleration of the effective date of the Registrant's Registration Statement on Form F-1 (File No. 333-281949) (as amended, the "Registration Statement"), relating to a public offering of ordinary shares of the Registrant, US$0.001 par value, so that the Registration Statement may be declared effective on June 9, 2025, at 8:30 a.m. Eastern Time, or as soon thereafter as practicable. The undersigned, as the Underwriter, confirms that it is aware of its obligations under the Securities Act.

Pursuant to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter, who is reasonably anticipated to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned confirms that it has complied with and will continue to comply with, and it has been informed or will be informed by participating dealers that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the above-referenced issue.

Very truly
yours,
Bancroft Capital, LLC

Show Raw Text
CORRESP
 1
 filename1.htm

 June
5, 2025

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attention:

 Mara Ransom

 Lilyanna Peyser

 Division of Corporate Finance

 Re:
 707 Cayman Holdings
 Limited

 Registration Statement
 on Form F-1, as amended (File No. 333-281949)

 Request for Acceleration
 of Effectiveness

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended (the "Securities Act"), we, the underwriter (the "Underwriter"),
hereby join in the request of 707 Cayman Holdings Limited (the "Registrant"), for the acceleration of the effective date
of the Registrant's Registration Statement on Form F-1 (File No. 333-281949) (as amended, the "Registration Statement"),
relating to a public offering of ordinary shares of the Registrant, US$0.001 par value, so that the Registration Statement may be declared
effective on June 9, 2025, at 8:30 a.m. Eastern Time, or as soon thereafter as practicable. The undersigned, as the Underwriter,
confirms that it is aware of its obligations under the Securities Act.

 Pursuant
to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter, who is reasonably anticipated
to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears
to be reasonable to secure adequate distribution of the preliminary prospectus.

 The
undersigned confirms that it has complied with and will continue to comply with, and it has been informed or will be informed by participating
dealers that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended,
in connection with the above-referenced issue.

 Very truly
 yours,

 Bancroft Capital, LLC

 /s/Robert
 L. Malin

 Name:
 Robert L. Malin

 Title:
 Managing Director, Investment
 Banking