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UPLOAD Filing

ETOILES CAPITAL GROUP CO., LTD
Date: May 2, 2025 · CIK: 0002058349 · Accession: 0000000000-25-004695

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
May 2, 2025
Author
Division of
Form
UPLOAD
Company
ETOILES CAPITAL GROUP CO., LTD

Letter

Re: Thrive Capital Group Co., Ltd Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted April 9, 2025 CIK No. 0002058349 Dear Kit Shing Cheung:

May 2, 2025

Kit Shing Cheung Chief Executive Officer Thrive Capital Group Co., Ltd Room 1109, 11/F, Tai Yau Building No. 181 Johnston Road, Wanchai, Hong Kong

We have reviewed your amended draft registration statement and have the following comment.

Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. 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 the information you provide in response to this letter and your amended draft registration statement or filed registration statement, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our April 3, 2025 letter.

Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted April 9, Cover Page

1. We note your revised disclosure in response to prior comment 3, as well as your disclosure on page 23 that you have paid dividends to your shareholders in the past. Please provide additional detail regarding these dividends, including quantifying the amounts. Please make similar disclosure in your section regarding cash transfers beginning on page 3. Alternatively, please confirm that payment of the dividends did not occur during the time period covered by the registration statement. May 2, 2025 Page 2

Please contact Amy Geddes at 202-551-3304 or Doug Jones at 202-551-3309 if you have questions regarding comments on the financial statements and related matters. Please contact Alyssa Wall at 202-551-8106 or Cara Wirth at 202-551-7127 with any other questions.

Sincerely,
Division of
Corporation Finance
Office of Trade &
Services
cc: Lawrence Venick

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

Kit Shing Cheung
Chief Executive Officer
Thrive Capital Group Co., Ltd
Room 1109, 11/F, Tai Yau Building
No. 181 Johnston Road, Wanchai, Hong Kong

 Re: Thrive Capital Group Co., Ltd
 Amendment No. 1 to Draft Registration Statement on Form F-1
 Submitted April 9, 2025
 CIK No. 0002058349
Dear Kit Shing Cheung:

 We have reviewed your amended draft registration statement and have the
following
comment.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. 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 the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our April 3, 2025 letter.

Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted April 9,
2025
Cover Page

1. We note your revised disclosure in response to prior comment 3, as well
as your
 disclosure on page 23 that you have paid dividends to your shareholders
in the past.
 Please provide additional detail regarding these dividends, including
quantifying
 the amounts. Please make similar disclosure in your section regarding
cash transfers
 beginning on page 3. Alternatively, please confirm that payment of the
dividends did
 not occur during the time period covered by the registration statement.
 May 2, 2025
Page 2

 Please contact Amy Geddes at 202-551-3304 or Doug Jones at 202-551-3309
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alyssa Wall at 202-551-8106 or Cara Wirth at 202-551-7127 with any
other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Lawrence Venick
</TEXT>
</DOCUMENT>