SEC Comment Letter for SIBO HOLDING Ltd (SIBO) (CIK 0002043392) — Jul 25, 2025
SIBO HOLDING Ltd (SIBO) (CIK 0002043392)
Date: July 25, 2025 · CIK: 0002043392 · Accession: 0000000000-25-007849
AI Filing Summary & Sentiment
Reasoning
Letter
July 25, 2025 Ju Liu Chairman of the Board Sibo Holding Limited Suite 3210, 32/F, Champion Tower 3 Garden Road, Central Hong Kong Re:Sibo Holding Limited Amendment No. 3 to Draft Registration Statement on Form F-1 Submitted July 9, 2025 CIK No. 0002043392 Dear Ju Liu: We have reviewed your amended draft registration statement and have the following comments. Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. 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 the information you provide in response to this letter and your amended draft registration statement or filed registration statement, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our June 30, 2025 letter. Amendment No. 3 to Draft Registration Statement on Form F-1 Note 12. Income Tax, page F-21 1.We note your response to prior comment 4 and that you have determined that a full valuation allowance remains appropriate as of December 31, 2024. Please revise to discuss the key evidence that you considered in determining the realizability of your deferred tax asset and the measurement of your valuation allowance. Refer to ASC 740-10-50-21 for guidance.
July 25, 2025 Page 2 2.We note your response to prior comment 5 and that the Inland Revenue Department has not reviewed any loss claims. Please revise to include a description of tax years that remain subject to examination by major tax jurisdiction(s) in accordance with ASC 740-10-50-15(e). Please contact Jee Yeon Ahn at 202-551-3673 or Michael Volley at 202-551-3437 if you have questions regarding comments on the financial statements and related matters. Please contact Aisha Adegbuyi at 202-551-8754 or Tonya Aldave at 202-551-3601 with any other questions. Sincerely, Division of Corporation Finance Office of Finance cc:Kevin (Qixiang) Sun, Esq.
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July 25, 2025
Ju Liu
Chairman of the Board
Sibo Holding Limited
Suite 3210, 32/F, Champion Tower
3 Garden Road, Central
Hong Kong
Re:Sibo Holding Limited
Amendment No. 3 to
Draft Registration Statement on Form F-1
Submitted July 9, 2025
CIK No. 0002043392
Dear Ju Liu:
We have reviewed your amended draft registration statement and have the following
comments.
Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. 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 the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in
our June 30, 2025 letter.
Amendment No. 3 to Draft Registration Statement on Form F-1
Note 12. Income Tax, page F-21
1.We note your response to prior comment 4 and that you have determined that a full
valuation allowance remains appropriate as of December 31, 2024. Please revise to
discuss the key evidence that you considered in determining the realizability of your
deferred tax asset and the measurement of your valuation allowance. Refer to ASC
740-10-50-21 for guidance.
July 25, 2025
Page 2
2.We note your response to prior comment 5 and that the Inland Revenue Department
has not reviewed any loss claims. Please revise to include a description of tax years
that remain subject to examination by major tax jurisdiction(s) in accordance with
ASC 740-10-50-15(e).
Please contact Jee Yeon Ahn at 202-551-3673 or Michael Volley at 202-551-3437 if
you have questions regarding comments on the financial statements and related
matters. Please contact Aisha Adegbuyi at 202-551-8754 or Tonya Aldave at 202-551-3601
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Kevin (Qixiang) Sun, Esq.