SEC Company Response from DT House Ltd (CIK 0002047713) — Aug 6, 2025
DT House Ltd (CIK 0002047713)
Date: Aug. 6, 2025 · CIK: 0002047713 · Accession: 0001213900-25-072684
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-285475
Referenced dates: July 8, 2025
Letter
Via EDGAR Division of Corporation Finance Office of Trade & Services Registration Statement on Form F-1 Response to the Staff’s Comments Dated July 8, 2025 File No. 333-285475
Re: DT House Limited
Dear Mr. Jones, Mr. Shenk and Ms. Reed:
On behalf of our client, DT House Limited (the “Company”), a foreign private issuer incorporated in the Cayman Islands (the “Company”), we submit to the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) this letter setting forth the Company’s responses to the comments contained in the Staff’s letter dated July 8, 2025 on the Company’s registration statement on Form F-1 submitted on June 18, 2025. Concurrently with the submission of this letter, the Company is filing its Amendment No.2 on Form F-1 (the “Amendment No.2”) and certain exhibits via EDGAR to the Commission.
The Staff’s comments from its letter dated July 8, 2025 are repeated below in bold and followed by the Company’s responses. We have included page numbers to refer to the location in the Amendment No.2 of the Registration Statement where the language addressing the comments appears. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Registration Statement.
Amendment No. 1 to Registration Statement on Form F-1 filed June 18, 2025
Business, page 72
1. Please restore disclosure regarding levels of dependence on your major customers to this section. In this regard, we note that you have removed disclosure that two major customers accounted for approximately 27% and 24% of total revenues for the year ended September 30, 2024.
In response to the Staff’s comment, the Company has reinstated the referenced disclosure regarding customer concentration on pages 1 and 77 of Amendment No.2. In addition, the Company has updated, among others, the disclosure to include the levels of dependence on its major customers for the six months ended June 30, 2025 on the same pages of Amendment No.2.
If you have any questions or further comments regarding the Amendment No.2 of the Registration Statement, please contact me by phone at +852 2230 3535 or via email at Virginia.Tam@klgates.com.
Very
truly yours,
/s/
Virginia Tam
Show Raw Text
CORRESP
1
filename1.htm
August 6, 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:
DT
House Limited
Registration
Statement on Form F-1
Response
to the Staff’s Comments Dated July 8, 2025
File No.
333-285475
Dear
Mr. Jones, Mr. Shenk and Ms. Reed:
On
behalf of our client, DT House Limited (the “Company”), a foreign private issuer incorporated in the Cayman Islands
(the “Company”), we submit to the staff (the “Staff”) of the U.S. Securities and Exchange Commission
(the “Commission”) this letter setting forth the Company’s responses to the comments contained in the Staff’s
letter dated July 8, 2025 on the Company’s registration statement on Form F-1 submitted on June 18, 2025. Concurrently with the
submission of this letter, the Company is filing its Amendment No.2 on Form F-1 (the “Amendment No.2”) and certain
exhibits via EDGAR to the Commission.
The
Staff’s comments from its letter dated July 8, 2025 are repeated below in bold and followed by the Company’s responses. We
have included page numbers to refer to the location in the Amendment No.2 of the Registration Statement where the language addressing
the comments appears. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Registration Statement.
Amendment
No. 1 to Registration Statement on Form F-1 filed June 18, 2025
Business,
page 72
1.
Please
restore disclosure regarding levels of dependence on your major customers to this section. In this regard, we note that you have
removed disclosure that two major customers accounted for approximately 27% and 24% of total revenues for the year ended September
30, 2024.
In response to the Staff’s
comment, the Company has reinstated the referenced disclosure regarding customer concentration on pages 1 and 77 of Amendment No.2.
In addition, the Company has updated, among others, the disclosure to include the levels of dependence on its major customers for the
six months ended June 30, 2025 on the same pages of Amendment No.2.
If
you have any questions or further comments regarding the Amendment No.2 of the Registration Statement, please contact me by phone at
+852 2230 3535 or via email at Virginia.Tam@klgates.com.
Very
truly yours,
/s/
Virginia Tam
Name:
Virginia
Tam
2
K&L
GATES, SOLICITORS 44th Floor Edinburgh Tower The Landmark 15 Queen’s Road Central Hong
Kong
高蓋茨律師事務所
香港中環皇后大道中15號 置地廣場公爵大廈44樓
T +852 2230
3500 F +852 2511 9515 klgates.com
Partners
Sacha
M. CHEONG
文錦明
William
Z. HO
何志淵
Virginia
M.L. TAM
譚敏亮
Sook
Young YEU
呂淑榮
Jay
C. CHIU
邱志藩
Jay
J. LEE
李再浩
Vincent
S.K. TSO
曹紹基
Eugene
Y.C. YEUNG
楊睿知
Janney
Y. CHONG
莊
怡
Scott
D. PETERMAN
畢德民
Christopher
TUNG
董彥華
Registered
Foreign Lawyer (PRC)
Registered
Foreign Lawyer (California (USA))
Amigo
L. XIE
謝
嵐
Roberta
A. CHANG
張
安
3