CORRESP Filing
Phoenix Asia Holdings Ltd
Date: April 22, 2025 · CIK: 0002035709 · Accession: 0001641172-25-005635
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-284260
Letter
Re: Phoenix Asia Holdings Limited
April 22, 2025
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
F Street, N.E.
Washington, D.C. 20549
Registration Statement on Form F-1, as amended
File No. 333- 284260
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended (the "Act"), D. Boral Capital LLC, as representatives of the several underwriters, hereby join Phoenix Asia Holdings Limited (the "Company") in requesting that the U.S. Securities and Exchange Commission take appropriate action to cause the Registration Statement on Form F-1, as amended (File No. 333-284260) (the "Registration Statement"), to become effective on April 24, 2025, at 4:00 p.m., Eastern Time, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, CFN Lawyers LLC, request by telephone that such Registration Statement be declared effective.
Pursuant to Rule 460 under the Securities Act, we wish to advise you that we have distributed as many copies of the Preliminary Prospectus dated April 9, 2025, to selected dealers, institutions and others as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus.
The undersigned advises that they have complied and will continue to comply, and that they have been informed by the participating underwriters and dealers that they have complied with and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
Very
truly yours,
D.
Boral Capital LLC
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CORRESP 1 filename1.htm April 22, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Re: Phoenix Asia Holdings Limited Registration Statement on Form F-1, as amended File No. 333- 284260 Ladies and Gentlemen: In accordance with Rule 461 under the Securities Act of 1933, as amended (the "Act"), D. Boral Capital LLC, as representatives of the several underwriters, hereby join Phoenix Asia Holdings Limited (the "Company") in requesting that the U.S. Securities and Exchange Commission take appropriate action to cause the Registration Statement on Form F-1, as amended (File No. 333-284260) (the "Registration Statement"), to become effective on April 24, 2025, at 4:00 p.m., Eastern Time, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, CFN Lawyers LLC, request by telephone that such Registration Statement be declared effective. Pursuant to Rule 460 under the Securities Act, we wish to advise you that we have distributed as many copies of the Preliminary Prospectus dated April 9, 2025, to selected dealers, institutions and others as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus. The undersigned advises that they have complied and will continue to comply, and that they have been informed by the participating underwriters and dealers that they have complied with and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. Very truly yours, D. Boral Capital LLC By: /s/ Stephanie Hu Name: Stephanie Hu Title: Co-Head of Investment Banking