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SEC Comment Letter 0000000000-25-001150 to Euroholdings Ltd. (EHLD) (CIK 0002032779) (EHLD)

Euroholdings Ltd. (EHLD) (CIK 0002032779)
Date: Feb. 3, 2025 · CIK: 0002032779 · Accession: 0000000000-25-001150

AI Filing Summary & Sentiment

File numbers found in text: 001-42465

Date
February 3, 2025
Author
Not clearly detected
Form
UPLOAD
Company
Euroholdings Ltd. (EHLD) (CIK 0002032779)

Letter

February 3, 2025 Aristides Pittas Chief Executive Officer Euroholdings Ltd. 4, Messogiou & Evropis Street Maroussi, 15124 Greece Re:Euroholdings Ltd. Amendment No. 1 to Registration Statement on Form 20-F Filed January 21, 2025 File No. 001-42465 Dear Aristides Pittas: We have reviewed your filing and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response and any amendment you may file in response to this letter, we may have additional comments. Amendment No. 1 to Registration Statement on Form 20-F Item 6. Directors, Senior Management and Employees, page 80 1.Please update your employee disclosures for the fiscal year ended December 31, 2024. Refer to Item 6(d) of Form 20-F for guidance.

February 3, 2025 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Myra Moosariparambil at 202-551-3796 or Craig Arakawa at 202-551- 3650 if you have questions regarding comments on the financial statements and related matters. Please contact Claudia Rios at 202-551-8770 or Irene Barberena-Meissner at 202- 551-6548 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc:Anthony Tu-Sekine, Esq.

Show Raw Text
February 3, 2025
Aristides Pittas
Chief Executive Officer
Euroholdings Ltd.
4, Messogiou & Evropis Street
Maroussi, 15124
Greece
Re:Euroholdings Ltd.
Amendment No. 1 to Registration Statement on Form 20-F
Filed January 21, 2025
File No. 001-42465
Dear Aristides Pittas:
            We have reviewed your filing and have the following comment.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response and any amendment you may file in response to this
letter, we may have additional comments.
Amendment No. 1 to Registration Statement on Form 20-F
Item 6. Directors, Senior Management and Employees, page 80
1.Please update your employee disclosures for the fiscal year ended December 31, 2024.
Refer to Item 6(d) of Form 20-F for guidance.

February 3, 2025
Page 2
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Please contact Myra Moosariparambil at 202-551-3796 or Craig Arakawa at 202-551-
3650 if you have questions regarding comments on the financial statements and related
matters. Please contact Claudia Rios at 202-551-8770 or Irene Barberena-Meissner at 202-
551-6548 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Anthony Tu-Sekine, Esq.