Correspondence 0001213900-24-105543 from Intercont (Cayman) Ltd (NCT)
Intercont (Cayman) Ltd
Date: Dec. 4, 2024 · CIK: 0002018529 · Accession: 0001213900-24-105543
AI Filing Summary & Sentiment
Referenced dates: November 25, 2024
Letter
Suite 1919, 45 Rockefeller Plaza
630 Fifth Avenue
New York, NY 10111, USA
T: (1-737) 215-8491
F: (1-917) 672-3642
VIA EDGAR
December 4, 2024
Division of Corporation Finance
Office of Energy & Transportation
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn: Cheryl Brown, Liz Packebusch
Re: Intercont (Cayman) Limited
Amendment No.2 to Registration Statement on Form F-1
Filed on November 15, 2024
CIK No. 0002018529
Ladies and Gentlemen:
On behalf of our client, Intercont (Cayman) Limited (the “Company”), a company incorporated in the Cayman Islands, we are submitting to the Staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”) this letter setting forth the Company’s responses to the comments contained in the Staff’s letter dated November 25, 2024 (the “Comment Letter”) on the Company’s Amendment No.2 to Registration Statement on Form F-1 filed on November 15, 2024 (the “Registration Statement”).
Concurrently with the submission of this letter, the Company is submitting via EDGAR the Amendment No.3 to Registration Statement (the “Revised Registration Statement”). The Company has responded to all of the Staff’s comments by revising the Registration Statement to address the comments, or by providing an explanation if the Company has not so revised the Registration Statement. For ease of reference, each comment contained in the Comment Letter is printed below in bold, followed by the Company’s responses to such comment. All page references in the responses set forth below refer to the page numbers in the Revised Registration Statement.
Exhibit Index, Page II-5
1. Please note that, prior to effectiveness, you will need to file an updated auditor consent.
In response to the Staff’s comment, the Company has filed an updated auditor consent as Exhibit 23.1 to the Revised Registration Statement.
If you have any questions regarding this submission, please contact Lan Lou at (917) 661-8175 or loul@junhe.com.
Thank you again for your time and attention.
Yours sincerely,
/s/ Lan Lou
Lan Lou
Partner
Jun He Law Offices LLC
cc:
Muchun Zhu, Chairman of the Board and Chief Executive Officer, Intercont (Cayman) Limited
Michael Burke, Partner, UHY LLP
Jason Ye, Ortoli Rosenstadt LLP
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Suite 1919, 45 Rockefeller Plaza
630 Fifth Avenue
New York, NY 10111, USA
T: (1-737) 215-8491
F: (1-917) 672-3642
VIA EDGAR
December 4, 2024
Division of Corporation Finance
Office of Energy & Transportation
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn: Cheryl Brown, Liz Packebusch
Re: Intercont
(Cayman) Limited
Amendment No.2 to Registration Statement on
Form F-1
Filed on November 15, 2024
CIK No. 0002018529
Ladies and Gentlemen:
On behalf of our client, Intercont (Cayman) Limited
(the “Company”), a company incorporated in the Cayman Islands, we are submitting to the Staff of the Division of Corporation
Finance of the Securities and Exchange Commission (the “Staff”) this letter setting forth the Company’s responses to
the comments contained in the Staff’s letter dated November 25, 2024 (the “Comment Letter”) on the Company’s Amendment
No.2 to Registration Statement on Form F-1 filed on November 15, 2024 (the “Registration Statement”).
Concurrently with the submission of this letter,
the Company is submitting via EDGAR the Amendment No.3 to Registration Statement (the “Revised Registration Statement”). The
Company has responded to all of the Staff’s comments by revising the Registration Statement to address the comments, or by providing
an explanation if the Company has not so revised the Registration Statement. For ease of reference, each comment contained in the Comment
Letter is printed below in bold, followed by the Company’s responses to such comment. All page references in the responses set forth
below refer to the page numbers in the Revised Registration Statement.
Exhibit Index, Page II-5
1.
Please note that, prior to effectiveness, you will need to file an updated auditor consent.
In response to the Staff’s comment,
the Company has filed an updated auditor consent as Exhibit 23.1 to the Revised Registration Statement.
If you have any questions regarding this submission,
please contact Lan Lou at (917) 661-8175 or loul@junhe.com.
Thank you again for your
time and attention.
Yours sincerely,
/s/ Lan Lou
Lan Lou
Partner
Jun He Law Offices LLC
cc:
Muchun Zhu, Chairman of the Board and Chief Executive Officer, Intercont
(Cayman) Limited
Michael Burke, Partner, UHY LLP
Jason Ye, Ortoli Rosenstadt LLP