SEC Comment Letter 0000000000-24-011381 to Intercont (Cayman) Ltd (NCT)
Intercont (Cayman) Ltd
Date: Oct. 8, 2024 · CIK: 0002018529 · Accession: 0000000000-24-011381
AI Filing Summary & Sentiment
File numbers found in text: 333-282394
Letter
October 8, 2024 Muchun Zhu Chief Executive Officer Intercont (Cayman) Limited Room 8501, 11/F., Capital Centre 151 Gloucester Road Wanchai, Hong Kong Re:Intercont (Cayman) Limited Registration Statement on Form F-1 Filed September 27, 2024 File No. 333-282394 Dear Muchun Zhu: 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 August 9, 2024 letter. Registration Statement on Form F-1 filed September 27, 2024 Cover Page 1.We note your response to prior comment 1 and reissue it in part. Please revise to clarify that all of the legal and operational risks associated with operating in the PRC also apply to your operations in Hong Kong. In this regard we note your revised disclosure indicating that, "[t]o the extent applicable," all of the legal and operational risks associated in operating in the PRC also apply to the operations of your Hong Kong Subsidiaries.
October 8, 2024 Page 2 Financial Statements, page F-1 2.Please update the financial statements and related disclosures included in the registration statement in accordance with the guidance outlined in Item 8.A. to Form 20-F. Please contact Joseph Klinko at 202-551-3824 or Robert Babula at 202-551-3339 if you have questions regarding comments on the financial statements and related matters. Please contact Cheryl Brown at 202-551-3905 or Liz Packebusch at 202-551-8749 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc:Lan Lou
Show Raw Text
October 8, 2024
Muchun Zhu
Chief Executive Officer
Intercont (Cayman) Limited
Room 8501, 11/F., Capital Centre
151 Gloucester Road
Wanchai, Hong Kong
Re:Intercont (Cayman) Limited
Registration Statement on Form F-1
Filed September 27, 2024
File No. 333-282394
Dear Muchun Zhu:
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 August 9, 2024 letter.
Registration Statement on Form F-1 filed September 27, 2024
Cover Page
1.We note your response to prior comment 1 and reissue it in part. Please revise to
clarify that all of the legal and operational risks associated with operating in the PRC
also apply to your operations in Hong Kong. In this regard we note your revised
disclosure indicating that, "[t]o the extent applicable," all of the legal and operational
risks associated in operating in the PRC also apply to the operations of your Hong
Kong Subsidiaries.
October 8, 2024
Page 2
Financial Statements, page F-1
2.Please update the financial statements and related disclosures included in the
registration statement in accordance with the guidance outlined in Item 8.A. to Form
20-F.
Please contact Joseph Klinko at 202-551-3824 or Robert Babula at 202-551-3339 if
you have questions regarding comments on the financial statements and related
matters. Please contact Cheryl Brown at 202-551-3905 or Liz Packebusch at 202-551-8749
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Lan Lou