SEC Company Response from ELC Group Holdings Ltd. (ELCG) (CIK 0002039096) — Sep 26, 2025
ELC Group Holdings Ltd. (ELCG) (CIK 0002039096)
Date: Sept. 26, 2025 · CIK: 0002039096 · Accession: 0001493152-25-015714
AI Filing Summary & Sentiment
File numbers found in text: 333-285524
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CORRESP
1
filename1.htm
September 26, 2025
VIA
EDGAR
Ms.
Ta Tanisha Meadows
Ms.
Joel Parker
Mr.
Scott Anderegg
Ms.
Taylor Beech
Division
of Corporation Finance
Office
of Trade & Services
U.S.
Securities and Exchange Commission
100
F Street, N.E.
Washington,
DC 20549
Re:
ELC
Group Holdings Ltd.
Amendment
No.7 to
Registration
Statement on Form F-1, as amended (File No. 333-285524)
Ladies
and Gentlemen:
Pursuant
to Rule 461 of the General Rules and Regulations (“Rule 461”) under the Securities Act of 1933, as amended, ELC Group
Holdings Ltd. (the “Company”) hereby requests that the Securities and Exchange Commission (the “Commission”)
take appropriate action to cause the above-referenced Registration Statement on Form F-1, as amended (the “Registration Statement”)
to become effective at 4:00 p.m. Eastern Time, on September 30, 2025, or as soon thereafter as practicable.
If
there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the
Company may be making an oral request of acceleration of the effectiveness of the Registration Statement in accordance with Rule 461.
Such request may be made by an executive officer of the Company or by any attorney from the Company’s U.S. counsel, Morgan, Lewis
& Bockius.
The
Company understands that the representative of the underwriters, on behalf of the prospective underwriters of the offering, has joined
in this request in a separate letter filed with the Commission today.
Please
contact Ms. Louise Liu of Morgan, Lewis & Bockius at +852.3551.8688 or via e-mail at louise.liu@morganlewis.com with any questions
you may have concerning this request. In addition, please notify Ms. Liu when this request for acceleration has been granted.
(Signature
page follows)
Very
truly yours,
ELC
Group Holdings Ltd.
By:
/s/
Leann Koh Bee Khee
Name:
Leann
Koh Bee Khee
Title:
Director
and Chief Executive Officer
(Signature
Page to Issuer Acceleration Request)