SEC Comment Letter for TryHard Holdings (THH) — Aug 1, 2025
TryHard Holdings Ltd
Date: Aug. 1, 2025 · CIK: 0002044241 · Accession: 0000000000-25-008139
AI Filing Summary & Sentiment
File numbers found in text: 333-287751
Letter
August 1, 2025 Rakuyo Otsuki Chief Executive Officer TryHard Holdings Ltd 541-0056, 2 Chome 5-19 Kyutaromachi Chuo Ward, Osaka Japan Re:TryHard Holdings Ltd Amendment No. 2 to Registration Statement on Form F-1 Filed July 21, 2025 File No. 333-287751 Dear Rakuyo Otsuki: We have reviewed your amended registration statement and have the following comment(s). 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. 2 to Registration Statement on Form F-1 Index to Consolidated Financial Statements, page F-1 1.We note your filing includes audited financial statements that are older than 12 months. Please update your financial statements in accordance with Item 8.A.4 of Form 20-F or include the representation noted in Instruction 2 to Item 8.A.4 as an exhibit to your registration statement.
August 1, 2025 Page 2 Please contact Aamira Chaudhry at 202-551-3389 or Theresa Brillant at 202-551- 3307 if you have questions regarding comments on the financial statements and related matters. Please contact Kate Beukenkamp at 202-551-3861 or Taylor Beech at 202-551-4515 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc:R. Joilene Wood
Show Raw Text
August 1, 2025
Rakuyo Otsuki
Chief Executive Officer
TryHard Holdings Ltd
541-0056, 2 Chome 5-19
Kyutaromachi
Chuo Ward, Osaka
Japan
Re:TryHard Holdings Ltd
Amendment No. 2 to Registration Statement on Form F-1
Filed July 21, 2025
File No. 333-287751
Dear Rakuyo Otsuki:
We have reviewed your amended registration statement and have the following
comment(s).
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. 2 to Registration Statement on Form F-1
Index to Consolidated Financial Statements, page F-1
1.We note your filing includes audited financial statements that are older than 12
months. Please update your financial statements in accordance with Item 8.A.4 of
Form 20-F or include the representation noted in Instruction 2 to Item 8.A.4 as an
exhibit to your registration statement.
August 1, 2025
Page 2
Please contact Aamira Chaudhry at 202-551-3389 or Theresa Brillant at 202-551-
3307 if you have questions regarding comments on the financial statements and related
matters. Please contact Kate Beukenkamp at 202-551-3861 or Taylor Beech at 202-551-4515
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:R. Joilene Wood