SEC Comment Letter 0000000000-25-001461 to Pitanium Ltd (PTNM)
Pitanium Ltd
Date: Feb. 11, 2025 · CIK: 0002046573 · Accession: 0000000000-25-001461
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February 11, 2025
Yuen Yi Young
Chairwoman and Director
Pitanium Limited
30F, Gravity, 29 Hing Yip Street
Kwun Tong, Kowloon, Hong Kong
Re:Pitanium Limited
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted February 3, 2025
CIK No. 0002046573
Dear Yuen Yi Young:
We have reviewed your amended draft registration statement and have the following
comment.
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 January 29, 2025 letter.
Draft Registration Statement on Form F-1 submitted February 3, 2025
General
1.Please file your exhibits in proper text-searchable format, including exhibits 10.11
and 10.12. Refer to Item 301 of Regulation S-T.
February 11, 2025
Page 2
Please contact Tayyaba Shafique at 202-551-2110 or Li Xiao at 202-551-4391 if you
have questions regarding comments on the financial statements and related matters. Please
contact Nicholas O'Leary at 202-551-4451 or Conlon Danberg at 202-551-4466 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Andrei Sirabionian, Esq.