SEC Company Response from SharonAI Holdings (SHAZ) — Sep 30, 2025
SharonAI Holdings Inc.
Date: Sept. 30, 2025 · CIK: 0002068385 · Accession: 0001829126-25-007795
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-287287
Letter
Division of Corporation Finance Office of Technology Re: Roth CH Holdings, Inc. Amendment No. 3 to Registration Statement on Form S-4 Filed September 11, 2025 File No. 333-287287
Dear Mr. Bassey,
We have set forth below responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) contained in its letter of September 25, 2025 with respect to the Amendment No. 3 to the Registration Statement on Form S-4 (the “Registration Statement”) filed with the SEC on September 11, 2025 by Roth CH Holdings, Inc., a Delaware corporation (the “Company,” “we,” “our” or “us”). For your convenience, the text of the Staff’s comments is set forth below followed in each case by the Company’s response. Please note that all references to page numbers in the responses are references to the page numbers in Amendment No. 4 to the Registration Statement (the “Amended Registration Statement”) filed with the SEC concurrently with the filing of this letter.
Amendment No. 3 to Form S-4
Distributed Storage Solutions Limited Consolidated Financial Statements
For the Six-Month Period Ended June 30, 2024
Consolidated Statements of Cash Flows, page F-146
1. We note your response to prior comment 7. Please make a similar revision to remove the subtotal of “Cash generated/(used) from operations” within the reconciliation to “Net cash flows from/(used in) operating activities.”
Response: We acknowledge the Staff’s comment and have revised the disclosures accordingly, see page F-146 of the Amended Registration Statement.
Should you have any questions relating to the foregoing or wish to discuss any aspect of the Company’s counsel Alexandria Kane, Esq. at Loeb & Loeb LLP Tel. No. (212) 407-4831 or Email: akane@loeb.com or James A. Prestiano, Esq. at Loeb & Loeb LLP Tel. No. (212) 407-4831 or Email: jpresitano@loeb.com.
Thank you for your time and attention to this filing.
Sincerely,
Roth CH Holdings, Inc.
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CORRESP
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filename1.htm
ROTH
CH HOLDINGS, INC.
2340
Collins Avenue, Suite 402
Miami,
FL 33141
September 30, 2025
Division
of Corporation Finance
Office
of Technology
U.S.
Securities & Exchange Commission
100
F Street, NE
Washington, D.C. 20549
Attn:
Uwem Bassey
Matthew Derby
Re:
Roth CH Holdings, Inc.
Amendment No. 3 to Registration Statement on Form S-4
Filed September 11, 2025
File No. 333-287287
Dear Mr. Bassey,
We have set forth below responses
to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”)
contained in its letter of September 25, 2025 with respect to the Amendment No. 3 to the Registration Statement on Form S-4 (the “Registration
Statement”) filed with the SEC on September 11, 2025 by Roth CH Holdings, Inc., a Delaware corporation (the “Company,”
“we,” “our” or “us”). For your convenience, the text of
the Staff’s comments is set forth below followed in each case by the Company’s response. Please note that all references to
page numbers in the responses are references to the page numbers in Amendment No. 4 to the Registration Statement (the “Amended
Registration Statement”) filed with the SEC concurrently with the filing of this letter.
Amendment
No. 3 to Form S-4
Distributed Storage Solutions Limited Consolidated Financial Statements
For
the Six-Month Period Ended June 30, 2024
Consolidated Statements of Cash Flows, page F-146
1.
We note your response to prior comment 7. Please make a similar revision to remove the subtotal of “Cash generated/(used) from operations” within the reconciliation to “Net cash flows from/(used in) operating activities.”
Response: We acknowledge the Staff’s
comment and have revised the disclosures accordingly, see page F-146 of the Amended Registration Statement.
Should you have any questions relating to the foregoing or wish to
discuss any aspect of the Company’s counsel Alexandria Kane, Esq. at Loeb & Loeb LLP Tel. No. (212) 407-4831 or Email: akane@loeb.com
or James A. Prestiano, Esq. at Loeb & Loeb LLP Tel. No. (212) 407-4831 or Email: jpresitano@loeb.com.
Thank you for your time and attention
to this filing.
Sincerely,
Roth CH Holdings, Inc.
/s/ John Lipman
Name:
John Lipman
Title:
Chief Executive Officer
cc:
Alexandria Kane