SEC Company Response from TDE GROUP Ltd (CIK 0002053475) — Aug 29, 2025
TDE GROUP Ltd (CIK 0002053475)
Date: Aug. 29, 2025 · CIK: 0002053475 · Accession: 0002053475-25-000009
AI Filing Summary & Sentiment
Referenced dates: May 13, 2025
Letter
Re:TDE Group Limited Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted May 2, 2025 CIK No. 0002053475
Erik L. Mengwall
Partner
345 Park Avenue New York, NY 10154
Direct 212.407.4050 Main 212.407.4000 Fax 212.407.4990 emengwall@loeb.com
August 29, 2025
U.S. Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services 100 F Street, N.E. Washington, D.C. 20549 Attn: Suying Li, Rufus Decker, Alyssa Wall and Donald Field
Ladies and Gentlemen:
On behalf of our client, TDE Group Limited (the “Company”), we hereby provide a response to the comments issued in the letter dated May 13, 2025 from the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Staff’s Letter”) regarding the above-referenced Amendment No. 2 to Draft Registration Statement on Form F-1 submitted May 2, 2025.
Contemporaneously, the Company is filing the Registration Statement via EDGAR (the “Amended Registration Statement”), which reflects the Company’s responses to the comments received by the Staff and certain updated information. For ease of reference, each comment contained in the Staff’s Letter is printed below and is followed by the Company’s response. All page references in the responses set forth below refer to the page numbers in the Amended Registration Statement.
241743008.1 245749-10001
U.S. Securities and Exchange Commission
August 29, 2025
Page 2
Amendment No. 2 to Draft Registration Statement on Form F-1
Capitalization, page 50
1.Please include bank borrowings as a component of your total capitalization and indebtedness. Refer to Item 3.B of Form 20-F.
Response: In response to the Staff’s comment, the Company has amended the disclosure on page 52 of the Amended Registration Statement.
Please call me at +1 (212) 407 4050 if you would like additional information with respect to any of the foregoing. Thank you.
Sincerely,
/s/ Erik Mengwall
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CORRESP 1 filename1.htm Erik L. Mengwall Partner 345 Park Avenue New York, NY 10154 Direct 212.407.4050 Main 212.407.4000 Fax 212.407.4990 emengwall@loeb.com August 29, 2025 U.S. Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services 100 F Street, N.E. Washington, D.C. 20549 Attn: Suying Li, Rufus Decker, Alyssa Wall and Donald Field Re:TDE Group Limited Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted May 2, 2025 CIK No. 0002053475 Ladies and Gentlemen: On behalf of our client, TDE Group Limited (the “Company”), we hereby provide a response to the comments issued in the letter dated May 13, 2025 from the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Staff’s Letter”) regarding the above-referenced Amendment No. 2 to Draft Registration Statement on Form F-1 submitted May 2, 2025. Contemporaneously, the Company is filing the Registration Statement via EDGAR (the “Amended Registration Statement”), which reflects the Company’s responses to the comments received by the Staff and certain updated information. For ease of reference, each comment contained in the Staff’s Letter is printed below and is followed by the Company’s response. All page references in the responses set forth below refer to the page numbers in the Amended Registration Statement. 241743008.1 245749-10001 U.S. Securities and Exchange Commission August 29, 2025 Page 2 Amendment No. 2 to Draft Registration Statement on Form F-1 Capitalization, page 50 1.Please include bank borrowings as a component of your total capitalization and indebtedness. Refer to Item 3.B of Form 20-F. Response: In response to the Staff’s comment, the Company has amended the disclosure on page 52 of the Amended Registration Statement. Please call me at +1 (212) 407 4050 if you would like additional information with respect to any of the foregoing. Thank you. Sincerely, /s/ Erik Mengwall Erik Mengwall Partner 241743008.1 245749-10001