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Correspondence 0001013762-25-003321 from Delixy Holdings Ltd (DLXY)

Delixy Holdings Ltd
Date: March 27, 2025 · CIK: 0002025218 · Accession: 0001013762-25-003321

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File numbers found in text: 333-283248

Date
March 27, 2025
Author
Bancroft Capital, LLC
Form
CORRESP
Company
Delixy Holdings Ltd

Letter

Re: Delixy Holdings Limited (the "Company")

March 27, 2025

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street NE

Washington, D.C. 20549

Registration Statement on Form F-1

File No. 333-283248

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the "Securities Act"), Bancroft Capital, LLC, as representative of the underwriters, hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it will become effective at 4:00 p.m. Eastern Time on March 31, 2025 or as soon thereafter as practicable, or at such later time as the Company or its counsel may request via telephone call to the staff.

Pursuant to Rule 460 under the Securities Act, we wish to advise you that the underwriters have distributed as many copies of the preliminary prospectus to underwriters, dealers, institutions, and others 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 underwriters 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.

[Signature Page Follows]

Very truly yours,
Bancroft Capital, LLC

Show Raw Text
CORRESP
 1
 filename1.htm

 March 27, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street NE

 Washington, D.C. 20549

 Re: Delixy Holdings Limited (the "Company")

 Registration Statement on Form F-1

 File No. 333-283248

 Ladies and Gentlemen:

 Pursuant to Rule 461 promulgated under the Securities
Act of 1933, as amended (the "Securities Act"), Bancroft Capital, LLC, as representative of the underwriters, hereby requests
acceleration of the effective date of the above-referenced Registration Statement so that it will become effective at 4:00 p.m. Eastern
Time on March 31, 2025 or as soon thereafter as practicable, or at such later time as the Company or its counsel may request via telephone
call to the staff.

 Pursuant to Rule 460 under the Securities Act, we wish
to advise you that the underwriters have distributed as many copies of the preliminary prospectus to underwriters, dealers, institutions,
and others 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 underwriters 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.

 [Signature Page Follows]

 Very truly yours,

 Bancroft Capital, LLC

 By:

 /s/ Robert L. Malin

 Name:
 Title:

 Robert L. Malin Managing Director

 [Signature Page to Acceleration Request]