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Correspondence 0001013762-25-002040 from AsiaStrategy (SORA)

AsiaStrategy
Date: March 25, 2025 · CIK: 0002033515 · Accession: 0001013762-25-002040

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File numbers found in text: 333-283448

Date
March 25, 2025
Author
Dominari Securities LLC
Form
CORRESP
Company
AsiaStrategy

Letter

Dominari Securities LLC

725 Fifth Avenue, 23rd Floor

New York, NY 10022

March 25, 2025

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:

Valeria Franks Angela Lumley Jenna Hough Dietrich King

Re: Top Win International Limited

Registration Statement on Form F-1, as amended

File No. 333-283448

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the "Act"), the undersigned representative of the underwriters of the offering hereby join in the request of Top Win International Limited (the "Company") that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 4:00 p.m., Eastern Time, on March 27, 2025, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Ortoli Rosenstadt LLP, requests by telephone that such Registration Statement be declared effective.

Pursuant to Rule 460 of the Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned advises that the several underwriters have complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

Very truly yours,
Dominari Securities LLC

Show Raw Text
CORRESP
 1
 filename1.htm

 Dominari Securities LLC

 725 Fifth Avenue, 23rd Floor

 New
York, NY 10022

 March 25, 2025

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention:

 Valeria Franks
 Angela Lumley
 Jenna Hough
 Dietrich King

 Re:
 Top Win International Limited

 Registration Statement on Form F-1, as amended

 File No. 333-283448

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and Regulations
under the Securities Act of 1933, as amended (the "Act"), the undersigned representative of the underwriters of the offering
hereby join in the request of Top Win International Limited (the "Company") that the effective date of the above-referenced
Registration Statement be accelerated so as to permit it to become effective at 4:00 p.m., Eastern Time, on March 27, 2025, or as soon
thereafter as practicable, or at such other time as the Company or its outside counsel, Ortoli Rosenstadt LLP, requests by telephone that
such Registration Statement be declared effective.

 Pursuant to Rule 460 of the Act, please be advised
that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution of the
security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of
the preliminary prospectus.

 The undersigned advises that the several underwriters
have complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 Very truly yours,

 Dominari Securities LLC

 as representatives of the several underwriters

 By:
 /s/ Eric Newman

 Name:
 Eric Newman

 Title:
 Executive Vice President, Global Head of Investment Banking