SEC Company Response from TryHard Holdings (THH) — Jul 21, 2025
TryHard Holdings Ltd
Date: July 21, 2025 · CIK: 0002044241 · Accession: 0001641172-25-020443
AI Filing Summary & Sentiment
File numbers found in text: 333-287751
Letter
TryHard Holdings Ltd
541-0056, 2 Chome 5−19
Kyutaromachi
Chuo Ward, Osaka
Japan
July 21, 2025
Via EDGAR
Division of Corporation Finance
Office of Trade & Services
U.S. Securities and Exchange Commission
F Street, NE
Washington, D.C., 20549
Re: TryHard Holdings Ltd
Registration Statement Form F-1, as amended
File No. 333-287751
Ladies and Gentlemen:
We have submitted a Registration Statement on Form F-1 on July 21, 2025 with the U.S. Securities and Exchange Commission (the “Commission”) simultaneously with this correspondence. Note that the only substantive change was to reduce the size of the resale offering from three resale shareholders to one, reducing the resale offering to 2,388,750 Ordinary Shares and a cybersecurity risk factor. Our response to the Commission’s prior comment regarding the analysis under Securities Act Rules Compliance and Disclosure Interpretations Question 612.09 remains the same as was submitted in the correspondence filed on June 25, 2025.
If you have any questions regarding the disclosure in the Registration Statement on Form F-1 filed herewith, please direct them to our counsel David Ficksman at 310-789-1290 or dficksman@troygould.com or Joilene Wood at 415-305-4651 or jwood@troygould.com.
Sincerely,
TryHard Holdings Ltd
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CORRESP
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filename1.htm
TryHard
Holdings Ltd
541-0056,
2 Chome 5−19
Kyutaromachi
Chuo
Ward, Osaka
Japan
July
21, 2025
Via
EDGAR
Division
of Corporation Finance
Office
of Trade & Services
U.S.
Securities and Exchange Commission
100
F Street, NE
Washington,
D.C., 20549
Re:
TryHard Holdings Ltd
Registration Statement
Form F-1, as amended
File No. 333-287751
Ladies
and Gentlemen:
We
have submitted a Registration Statement on Form F-1 on July 21, 2025 with the U.S. Securities and Exchange Commission (the “Commission”)
simultaneously with this correspondence. Note that the only substantive change was to reduce the size of the resale offering from three
resale shareholders to one, reducing the resale offering to 2,388,750 Ordinary Shares and a cybersecurity risk factor. Our response
to the Commission’s prior comment regarding the analysis under Securities Act Rules Compliance and Disclosure Interpretations Question
612.09 remains the same as was submitted in the correspondence filed on June 25, 2025.
If
you have any questions regarding the disclosure in the Registration Statement on Form F-1 filed herewith, please direct them to our counsel
David Ficksman at 310-789-1290 or dficksman@troygould.com or Joilene Wood at 415-305-4651 or jwood@troygould.com.
Sincerely,
TryHard Holdings Ltd
By:
/s/ Rakuyo
Otsuki
Rakuyo Otsuki
Chief Executive Officer
cc:
David L. Ficksman
R. Joilene Wood