Correspondence 0001493152-25-006979 from Pitanium Ltd (PTNM)
Pitanium Ltd
Date: Feb. 14, 2025 · CIK: 0002046573 · Accession: 0001493152-25-006979
AI Filing Summary & Sentiment
Referenced dates: February 11, 2025
Letter
United States Securities and Exchange Commission Division of Corporation Finance Office of Industrial Applications and Services Re: Pitanium Limited Draft Registration Statement on Form F-1 Submitted February 3, 2025 CIK No. 0002046573
Dear Messrs. Shafique, Xiao, O’Leary, and Danberg:
On behalf of our client, Pitanium Limited (the “Company”), we hereby provide a response to the comments issued in a letter dated February 11, 2025 (the “Staff’s Letter”) regarding the Company’s the Amendment No. 2 to the Draft Registration Statement on Form F-1 (the “DRS”). Contemporaneously, we are filing a public filing on Form F-1.
In order to facilitate the review by the staff of the Securities and Exchange Commission (the “Staff”), we have responded, on behalf of the Company, to the comments set forth in the Staff’s Letter on a point-by-point basis. The numbered paragraphs set forth below respond to the Staff’s comments and correspond to the numbered paragraph in the Staff’s 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
Response: The Company notes the Staff’s comment and has filed the exhibits in proper text-searchable format, including exhibits 10.11 and 10.12 in the Exhibit Index to the public filing on Form F-1.
Los Angeles New York Chicago Nashville Washington, DC San Francisco Beijing Hong Kong www.loeb.com
For the United States offices, a limited liability partnership including professional corporations. For Hong Kong office, a limited liability partnership.
United States Securities and Exchange Commission
February 14, 2025
Page 2
Please call me at 212-407-4089 or Norly Jean-Charles at 212-407-4271 if you would like additional information with respect to any of the foregoing. Thank you.
Sincerely,
/s/ Andrei Sirabionian, Esq.
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Loeb &
Loeb LLP
901 New York Avenue, N.W.
Washington, D.C. 20001
345 Park Avenue
New York, NY 10154
Main
Fax
Main
Fax
202.618.5000
202.217.2554
212.407.4000
212.407.4990
February 14, 2025
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Industrial Applications and Services
100 F Street, N.E.
Washington, D.C. 20549
Attn:
Tayyaba Shafique
Li Xiao
Nicholas O’Leary
Conlon Danberg
Re:
Pitanium Limited
Draft Registration Statement on Form F-1
Submitted February 3, 2025
CIK No. 0002046573
Dear Messrs. Shafique, Xiao, O’Leary, and Danberg:
On behalf of our client, Pitanium Limited (the “Company”),
we hereby provide a response to the comments issued in a letter dated February 11, 2025 (the “Staff’s Letter”)
regarding the Company’s the Amendment No. 2 to the Draft Registration Statement on Form F-1 (the “DRS”). Contemporaneously,
we are filing a public filing on Form F-1.
In order to facilitate the review by the staff of
the Securities and Exchange Commission (the “Staff”), we have responded, on behalf of the Company,
to the comments set forth in the Staff’s Letter on a point-by-point basis. The numbered paragraphs set forth below respond to the
Staff’s comments and correspond to the numbered paragraph in the Staff’s 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
Response: The Company
notes the Staff’s comment and has filed the exhibits in proper text-searchable format, including exhibits 10.11 and 10.12 in
the Exhibit Index to the public filing on Form F-1.
Los Angeles New York Chicago Nashville Washington,
DC San Francisco Beijing Hong Kong www.loeb.com
For the United States offices, a limited liability
partnership including professional corporations. For Hong Kong office, a limited liability partnership.
United States Securities and Exchange Commission
February 14, 2025
Page 2
Please call me at 212-407-4089 or Norly Jean-Charles
at 212-407-4271 if you would like additional information with respect to any of the foregoing. Thank you.
Sincerely,
/s/ Andrei Sirabionian, Esq.
Andrei Sirabionian, Esq.
Partner
cc: Yuen Yi Young, Chairwoman and Director of Pitanium
Limited