SEC Comment Letter 0000000000-26-001796 to Magnitude International Ltd (MAGH)
Magnitude International Ltd
Date: Feb. 23, 2026 · CIK: 0002046117 · Accession: 0000000000-26-001796
AI Filing Summary & Sentiment
File numbers found in text: 001-42770
Letter
February 23, 2026 Lim Say Wei Chief Executive Officer Magnitude International Ltd 27 Woodlands Industrial Park E1 #03-15 (Lobby B) Hiangkie Industrial Building Singapore 757718 Re:Magnitude International Ltd Form 20-F for the fiscal year ended April 30, 2025 File No. 001-42770 Dear Lim Say Wei: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 20-F for the fiscal year ended April 30, 2025 Item 15. Controls and Procedures, page 76 1.Please amend your filing to disclose the conclusions of your principal executive and principal financial officers, or persons performing similar functions, regarding the effectiveness of your disclosure controls and procedures as of April 30, 2025. Please refer to Item 15(a) of Form 20-F. Item 16K. Cybersecurity, page 78 2.Please tell us why cybersecurity disclosure is not applicable given that Item 16K applies to annual reports on Form 20-F, or amend your filing to include the applicable cybersecurity disclosures. See Instruction to Item 16K of Form 20-F. Exhibits We note the certifications required by Rules 13a-14 and 15d-14 of the Exchange Act have been omitted from your Form 20-F. Please file an amended Form 20-F in its entirety and include the certifications from your principal executive officer and principal 3.
February 23, 2026 Page 2 financial officer, or persons performing similar functions, as exhibits in accordance with the general instructions and instructions as to exhibits of Form 20-F. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Jeffrey Lewis at 202-551-6216 or Jennifer Monick at 202-551-3295 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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February 23, 2026
Lim Say Wei
Chief Executive Officer
Magnitude International Ltd
27 Woodlands Industrial Park E1
#03-15 (Lobby B) Hiangkie Industrial Building
Singapore 757718
Re:Magnitude International Ltd
Form 20-F for the fiscal year ended April 30, 2025
File No. 001-42770
Dear Lim Say Wei:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 20-F for the fiscal year ended April 30, 2025
Item 15. Controls and Procedures, page 76
1.Please amend your filing to disclose the conclusions of your principal executive and
principal financial officers, or persons performing similar functions, regarding the
effectiveness of your disclosure controls and procedures as of April 30, 2025. Please
refer to Item 15(a) of Form 20-F.
Item 16K. Cybersecurity, page 78
2.Please tell us why cybersecurity disclosure is not applicable given that Item 16K
applies to annual reports on Form 20-F, or amend your filing to include the applicable
cybersecurity disclosures. See Instruction to Item 16K of Form 20-F.
Exhibits
We note the certifications required by Rules 13a-14 and 15d-14 of the Exchange Act
have been omitted from your Form 20-F. Please file an amended Form 20-F in its
entirety and include the certifications from your principal executive officer and principal 3.
February 23, 2026
Page 2
financial officer, or persons performing similar functions, as exhibits in accordance
with the general instructions and instructions as to exhibits of Form 20-F.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please contact Jeffrey Lewis at 202-551-6216 or Jennifer Monick at 202-551-3295 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction