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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

Offering / Registration Process

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File numbers found in text: 333-285524

Date
September 26, 2025
Author
ELC
Form
CORRESP
Company
ELC Group Holdings Ltd. (ELCG) (CIK 0002039096)

Letter

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

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.

Show Raw Text
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)