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SEC Company Response from EvoNexus Group (EVON) — Sep 24, 2025

EvoNexus Group LTD
Date: Sept. 24, 2025 · CIK: 0002075036 · Accession: 0001185185-25-001278

AI Filing Summary & Sentiment

File numbers found in text: 333-290099

Referenced dates: September 17, 2025

Date
Sept. 24, 2025
Author
Chief
Form
CORRESP
Company
EvoNexus Group LTD

Letter

Via EDGAR Division of Corporation Finance Office of Technology Attention: Joseph Cascarano Re: EvoNexus Group LTD Registration Statement on Form F-1 Filed September 8, 2025 File No. 333-290099

Dear sirs and madams:

This letter is in response to the letter dated September 17, 2025, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) addressed to EvoNexus Group LTD (the “Company,” “we,” and “our”). For ease of reference, we have recited the Commission’s comment in this response. Amendment No. 1 to Registration Statement on Form F-1 (the “Amendment No. 1”) is being publicly filed to accompany this letter.

Registration Statement on Form F-1

Risk Factors

If we cannot satisfy, or continue to satisfy, the initial listing requirements and other rules of Nasdaq..., page 39

1. We note that Nasdaq recently proposed a new rule that would require companies principally operating in China, including Hong Kong and Macau, to raise at least $25 million in an initial public offering to list on Nasdaq. Please revise your risk factor to address the potential effects this proposal could have on your ability to list and maintain a listing on the Nasdaq Capital Market Exchange.

Response: In response to the Staff’s comments, we have amended our disclosure on page 39 of the Amendment No. 1 accordingly.

We appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2206.

Very
truly yours,
/s/
Chong Li

Show Raw Text
CORRESP
1
filename1.htm

EvoNexus
Group LTD

September
24, 2025

Via
EDGAR

Division
of Corporation Finance

Office
of Technology

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C., 20549

    Attention:
    Joseph
    Cascarano

    Robert
    Littlepage

    Alexandra Barone

    Jan Woo

    Re:
    EvoNexus
    Group LTD

    Registration
    Statement on Form F-1

    Filed
    September 8, 2025

    File
    No. 333-290099

Dear
sirs and madams:

This
letter is in response to the letter dated September 17, 2025, from the staff (the “Staff”) of the U.S. Securities and Exchange
Commission (the “Commission”) addressed to EvoNexus Group LTD (the “Company,” “we,” and “our”).
For ease of reference, we have recited the Commission’s comment in this response. Amendment No. 1 to Registration Statement on
Form F-1 (the “Amendment No. 1”) is being publicly filed to accompany this letter.

Registration
Statement on Form F-1

Risk
Factors

If
we cannot satisfy, or continue to satisfy, the initial listing requirements and other rules of Nasdaq..., page 39

1.
We note that Nasdaq recently proposed a new rule that would require companies principally operating in China, including Hong Kong and
Macau, to raise at least $25 million in an initial public offering to list on Nasdaq. Please revise your risk factor to address the potential
effects this proposal could have on your ability to list and maintain a listing on the Nasdaq Capital Market Exchange.

Response:
In response to the Staff’s comments, we have amended our disclosure on page 39 of the Amendment No. 1 accordingly.

We
appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel,
Ying Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2206.

Very
truly yours,

    /s/
    Chong Li

    Name:
    Chong
    Li

    Title:
    Chief
    Executive Officer

    cc:
    Ying
    Li, Esq.

    Hunter
    Taubman Fischer & Li LLC