SEC Company Response from Nidar Infrastructure Ltd (CIK 0002042648) — Oct 17, 2025
Nidar Infrastructure Ltd (CIK 0002042648)
Date: Oct. 17, 2025 · CIK: 0002042648 · Accession: 0001104659-25-100474
AI Filing Summary & Sentiment
File numbers found in text: 333-283189
Referenced dates: July 23, 2025
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CORRESP
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filename1.htm
October 17, 2025
VIA EDGAR
Joseph Cascarano
Robert Littlepage
Uwem Bassey
Jeff Kauten
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Technology
100 F Street, N.E.
Washington, D.C. 20549
Re:
Nidar Infrastructure Limited
Amendment No. 2 to Registration Statement on Form F-4
Filed June 30, 2025
File No. 333-283189
Dear Mr. Cascarano:
This letter is in response
to the comments of the staff of the United States Securities and Exchange Commission (the “Staff”) contained in your
letter dated July 23, 2025 (the “Comment Letter”), regarding Amendment No. 2 to Registration Statement on
Form F-4 (the “Registration Statement”), which was filed by Nidar Infrastructure Limited (the “Company”
or “Nidar”) with the United States Securities and Exchange Commission (the “Commission”) on June 30,
2025.
The Company has filed today
Amendment No. 3 to the Registration Statement (“Amendment No. 3”) together with this letter via EDGAR correspondence.
For the convenience of the Staff, the numbering of the paragraphs below corresponds to the numbering of the comment in the Comment Letter,
the text of which the Company has incorporated into this response letter in italicized type, and which is followed by the Company’s
response. Unless otherwise indicated, all page references in the responses are to page numbers in Amendment No. 3. Capitalized
terms used herein but not defined shall have the meanings ascribed to them in Amendment No. 3.
Amendment No. 2 to Registration Statement on Form F-4
Information About Nidar
Nidar's Existing Data Center Business, page 221:
1. Comment: We note several instances
where you disclose annual recurring revenue (ARR), defined as “annualized contractual
revenue.” Please address the following:
· Disclose whether management considers ARR
a key operating metric.
· Clarify how this measure is calculated.
· Disclose the length of a typical contract
term and explain how you consider contract renewals in your ARR calculations.
· Clarify whether ARR reflects any actual or
anticipated reductions of revenue due to contract non-renewals or cancellations, and discuss any limitations present as a result.
· Revise to describe how ARR differs from IFRS
revenue.
Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on pages 222 and 223 of Amendment No. 3 to provide the requested information
regarding ARR.
Financial Statements, page F-1
2. Comment: Please provide updated audited financial statements for Nidar Infrastructure Limited
for the years ended March 31, 2025 pursuant to Item 8.A.4 of Form 20-F. Please similarly update all financial information throughout
your filing including pro forma financial information for the periods presented.
Response: The Company acknowledges
the Staff’s comment and has revised the disclosure in Amendment No. 3 to include audited financial statements for Nidar Infrastructure
Limited for the two years ended March 31, 2025 and update all financial information throughout Amendment No. 3 to include pro
forma financial information for the periods presented.
If you have any questions
regarding the responses to the comments of the Staff, or require additional information, please contact me by phone at (713) 354 –
4893.
Sincerely,
/s/ Taylor Landry
Taylor Landy
cc:
Sunil Gupta (Nidar Infrastructure Limited)