SEC Comment Letter 0000000000-25-002487 to PHAOS TECHNOLOGY HOLDINGS (CAYMAN) Ltd (POAS)
PHAOS TECHNOLOGY HOLDINGS (CAYMAN) Ltd
Date: March 6, 2025 · CIK: 0002024258 · Accession: 0000000000-25-002487
AI Filing Summary & Sentiment
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File numbers found in text: 333-284137
Letter
March 6, 2025 Andrew Yeo Chief Executive Officer Phaos Technology Holdings (Cayman) Ltd 83 Science Park Dr, #02-01 & #04-01A/B The Curie, Singapore Science Park 1 Singapore 118258 Re:Phaos Technology Holdings (Cayman) Ltd Amendment No. 1 to Registration Statement on Form F-1 Filed February 19, 2025 File No. 333-284137 Dear Andrew Yeo: We have reviewed your amended registration statement and have the following comments. 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 23, 2025 letter. Amendment No. 1 to Registration Statement on Form F-1 filed February 19, 2025 Financial Statements, page F-1 1.Please update the financial statements pursuant to the guidance in Item 8.A.5 of Form 20-F. See also Item 4 of Form F-1. General 2.We note your response to comment 6, but it does not appear to be completely responsive to our comment. Please refile your exhibits in text-searchable format. In this regard, we note that exhibits 3.1, 10.1-10.13, 10.15-10.16, and 10.18-10.22 are not in text-searchable format. See Item 301 of Regulation S-T.
March 6, 2025 Page 2 Please contact Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355 if you have questions regarding comments on the financial statements and related matters. Please contact Robert Augustin at 202-551-8483 or Katherine Bagley at 202-551-2545 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc:William S. Rosenstadt
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March 6, 2025
Andrew Yeo
Chief Executive Officer
Phaos Technology Holdings (Cayman) Ltd
83 Science Park Dr,
#02-01 & #04-01A/B The Curie, Singapore Science Park 1
Singapore 118258
Re:Phaos Technology Holdings (Cayman) Ltd
Amendment No. 1 to Registration Statement on Form F-1
Filed February 19, 2025
File No. 333-284137
Dear Andrew Yeo:
We have reviewed your amended registration statement and have the following
comments.
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 23, 2025 letter.
Amendment No. 1 to Registration Statement on Form F-1 filed February 19, 2025
Financial Statements, page F-1
1.Please update the financial statements pursuant to the guidance in Item 8.A.5 of Form
20-F. See also Item 4 of Form F-1.
General
2.We note your response to comment 6, but it does not appear to be completely
responsive to our comment. Please refile your exhibits in text-searchable format. In
this regard, we note that exhibits 3.1, 10.1-10.13, 10.15-10.16, and 10.18-10.22 are
not in text-searchable format. See Item 301 of Regulation S-T.
March 6, 2025
Page 2
Please contact Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355 if you
have questions regarding comments on the financial statements and related matters. Please
contact Robert Augustin at 202-551-8483 or Katherine Bagley at 202-551-2545 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:William S. Rosenstadt