SEC Comment Letter for ELC Group Holdings Ltd. (ELCG) (CIK 0002039096) — Jul 11, 2025
ELC Group Holdings Ltd. (ELCG) (CIK 0002039096)
Date: July 11, 2025 · CIK: 0002039096 · Accession: 0000000000-25-007353
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File numbers found in text: 333-285524
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July 11, 2025
Leann Koh Bee Khee
Chief Executive Officer
ELC Group Holdings Ltd.
745 Lor 5 Toa Payoh
#03-02 The Lifeline Building
Singapore 319455
Re:ELC Group Holdings Ltd.
Amendment No. 3 to Registration Statement on Form F-1
Filed July 9, 2025
File No. 333-285524
Dear Leann Koh Bee Khee:
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.
Amendment No. 3 to Registration Statement on Form F-1
Use of Proceeds, page 33
1.You appear to be stating gross proceeds. Please revise to present the net proceeds
consistent with the $3.6 million on page 35.
July 11, 2025
Page 2
Please contact Ta Tanisha Meadows at 202-551-3322 or Joel Parker at 202-551-3651
if you have questions regarding comments on the financial statements and related
matters. Please contact Scott Anderegg at 202-551-3342 or Taylor Beech at 202-551-4515
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services