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Correspondence 0001641172-25-012174 from GrowHub Ltd (TGHL)

GrowHub Ltd
Date: May 23, 2025 · CIK: 0002024114 · Accession: 0001641172-25-012174

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File numbers found in text: 333-286923

Referenced dates: May 22, 2025

Date
May 2, 2025
Author
Lawrence S. Venick
Form
CORRESP
Company
GrowHub Ltd

Letter

Division of Corporation Finance Office of Technology Securities and Exchange Commission Registration Statement on Form F-1 Filed May 2, 2025 File No. 333-286923

Re: The GrowHub Limited

Dear SEC Officers:

On behalf of GrowHub Limited (the “Company”), we have set forth below responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission contained in its letter dated May 22, 2025 with respect to the Registration Statement on Form F-1, File No. 333-286923 (“F-1”), submitted on May 2, 2025 by the Company. For your convenience, the text of the Staff’s comments is set forth below in bold, followed in each case by the Company’s responses. Please note that all references to page numbers in the responses are references to the page numbers in revised Form F-1 (the “Revised F-1”), filed concurrently with the submission of this letter in response to the Staff’s comments.

Registration Statement on Form F-1

General

1. Please supplementally provide us with copies of all written communications, as defined in Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf, present to potential investors in reliance on Section 5(d) of the Securities Act, whether or not they retain copies of the communications.

Response: In response to the Staff’s comment, the Company respectfully submits that there were no written communications, as defined in Rule 405 under the Securities Act, that we, or anyone authorized to do so on our behalf, were presented to potential investors in reliance on Section 5(d) of the Securities Act.

Should you have any questions relating to the foregoing or wish to discuss any aspect of the Company’s filing, please contact me at +852.5600.0188.

Very
truly yours,
/s/
Lawrence S. Venick

Show Raw Text
CORRESP
1
filename1.htm

May
23, 2025

Division
of Corporation Finance

Office
of Technology

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    The
    GrowHub Limited

    Registration
    Statement on Form F-1

    Filed
    May 2, 2025

    File
    No. 333-286923

Dear
SEC Officers:

On
behalf of GrowHub Limited (the “Company”), we have set forth below responses to the comments of the staff (the “Staff”)
of the Securities and Exchange Commission contained in its letter dated May 22, 2025 with respect to the Registration Statement on Form
F-1, File No. 333-286923 (“F-1”), submitted on May 2, 2025 by the Company. For your convenience, the text of the Staff’s
comments is set forth below in bold, followed in each case by the Company’s responses. Please note that all references to page
numbers in the responses are references to the page numbers in revised Form F-1 (the “Revised F-1”), filed concurrently with
the submission of this letter in response to the Staff’s comments.

Registration
Statement on Form F-1

General

    1.
    Please
    supplementally provide us with copies of all written communications, as defined in Rule 405 under the Securities Act, that you, or
    anyone authorized to do so on your behalf, present to potential investors in reliance on Section 5(d) of the Securities Act, whether
    or not they retain copies of the communications.

Response:
In response to the Staff’s comment, the Company respectfully submits that there were no written communications, as defined in Rule
405 under the Securities Act, that we, or anyone authorized to do so on our behalf, were presented to potential investors in reliance
on Section 5(d) of the Securities Act.

Should
you have any questions relating to the foregoing or wish to discuss any aspect of the Company’s filing, please contact me at +852.5600.0188.

    Very
    truly yours,

    /s/
    Lawrence S. Venick

    Lawrence
    S. Venick