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SEC Comment Letter 0000000000-25-003586 to BUUU Group Ltd (BUUU)

BUUU Group Ltd
Date: April 3, 2025 · CIK: 0002047273 · Accession: 0000000000-25-003586

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File numbers found in text: 333-286203

Date
April 3, 2025
Author
Finance
Form
UPLOAD
Company
BUUU Group Ltd

Letter

Re: BUUU Group Limited Registration Statement on Form F-1 Filed March 28, 2025 File No. 333-286203 Dear Chun Kit Yu:

April 3, 2025

Chun Kit Yu Chief Financial Officer BUUU Group Limited Flat B, 16/F, Ford Glory Plaza 37 Wing Hong Street Cheung Sha Wan, Hong Kong

We have reviewed your 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.

Registration Statement on Form F-1 Dilution, page 59

1. Your net tangible book value per Class A Ordinary Share before the offering appears to be $.13 rather than $1.34. Please revise or advise. 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.

Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. April 3, 2025 Page 2

Please contact Amy Geddes at 202-551-3304 or Joel Parker at 202-551-3651 with any questions.

Sincerely,
Division of Corporation
Finance
Office of Trade &
Services
cc: Jason Ye

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 3, 2025

Chun Kit Yu
Chief Financial Officer
BUUU Group Limited
Flat B, 16/F, Ford Glory Plaza
37 Wing Hong Street
Cheung Sha Wan, Hong Kong

 Re: BUUU Group Limited
 Registration Statement on Form F-1
 Filed March 28, 2025
 File No. 333-286203
Dear Chun Kit Yu:

 We have reviewed your 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.

Registration Statement on Form F-1
Dilution, page 59

1. Your net tangible book value per Class A Ordinary Share before the
offering appears
 to be $.13 rather than $1.34. Please revise or advise.
 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.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 April 3, 2025
Page 2

 Please contact Amy Geddes at 202-551-3304 or Joel Parker at 202-551-3651
with
any questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Trade &
Services
cc: Jason Ye
</TEXT>
</DOCUMENT>