SEC Comment Letter for TDE GROUP Ltd (CIK 0002053475) — Sep 30, 2025
TDE GROUP Ltd (CIK 0002053475)
Date: Sept. 30, 2025 · CIK: 0002053475 · Accession: 0000000000-25-010648
AI Filing Summary & Sentiment
File numbers found in text: 333-289968
Letter
September 30, 2025 Kwok Tin Ming Chief Executive Officer TDE Group Limited Unit 2101, 21/F The Bay Hub 17 Kai Cheung Road Kowloon Bay Hong Kong Re:TDE Group Limited Amendment No. 1 to Registration Statement on Form F-1 Filed September 22, 2025 File No. 333-289968 Dear Kwok Tin Ming: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe the 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. Unless we note otherwise, any references to prior comments are to comments in our September 19, 2025 letter. Amendment No. 1 to Registration Statement on Form F-1 Financial Statements, page F-1 1.Please update your financial statements in accordance with Item 8.A.4 of Form 20- F or include the representation noted in Instruction 2 to Item 8.A.4 of Form 20-F as an exhibit to your registration statement.
September 30, 2025 Page 2 Please contact Suying Li at 202-551-3335 or Rufus Decker at 202-551-3769 if you have questions regarding comments on the financial statements and related matters. Please contact Alyssa Wall at 202-551-8106 or Donald Field at 202-551-3680 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc:Erik Mengwall
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September 30, 2025
Kwok Tin Ming
Chief Executive Officer
TDE Group Limited
Unit 2101, 21/F
The Bay Hub
17 Kai Cheung Road
Kowloon Bay
Hong Kong
Re:TDE Group Limited
Amendment No. 1 to Registration Statement on Form F-1
Filed September 22, 2025
File No. 333-289968
Dear Kwok Tin Ming:
We have reviewed your amended registration statement and have the following
comment.
Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe the 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. Unless we note
otherwise, any references to prior comments are to comments in our September 19, 2025
letter.
Amendment No. 1 to Registration Statement on Form F-1
Financial Statements, page F-1
1.Please update your financial statements in accordance with Item 8.A.4 of Form 20-
F or include the representation noted in Instruction 2 to Item 8.A.4 of Form 20-F as an
exhibit to your registration statement.
September 30, 2025
Page 2
Please contact Suying Li at 202-551-3335 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alyssa Wall at 202-551-8106 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Erik Mengwall