SecProbe.io

CORRESP
 1
 filename1.htm

 June 25, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn: Rebekah Reed and Donald Field

 Re:
 Rich Sparkle Holdings Limited
 Request for Acceleration
Registration Statement on Form F-1, as amended (File No. 333-285592)

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and
Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended (the "Securities Act"),
Eddid Securities USA Inc., as representative of the underwriters, hereby requests acceleration of the effective date of the above-referenced
Registration Statement so that it will become effective at 4:30 p.m., Eastern Time on June 27, 2025, or as soon thereafter as practicable.

 Pursuant to Rule 460 of the General Rules and
Regulations under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably
anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears
to be reasonable to secure adequate distribution of the preliminary prospectus.

 The undersigned confirms that it has complied
and will continue to comply with, and it has been informed or will be informed by participating dealers that they have complied or will
comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the above-referenced issue.

 Very truly yours,

 Eddid Securities USA Inc.

 By:
 /s/ Tom Li

 Name:
 Tom Li

 Title:
 Chief Executive Officer

CORRESP
 1
 filename1.htm

 RICH SPARKLE HOLDINGS LIMITED

 VIA EDGAR

 June 25, 2025

 U.S. Securities & Exchange Commission

 Division of Corporation Finance

 Office of Trade & Services

 Washington, D.C. 20549

 Attn: Rebekah Reed and Donald Field

 Re:
 Rich Sparkle Holdings Limited

 Registration Statement on Form F-1

 Initially Filed March 6, 2025, as amended

 File No. 333-285592

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended, Rich Sparkle Holdings Limited hereby requests acceleration of effectiveness of the above referenced
Registration Statement so that it will become effective at 4:30 pm, Eastern Time, on June 27, 2025, or as soon as thereafter practicable.

 Very truly yours,

 /s/ Tsz Keung CHAN

 Tsz Keung CHAN

 Chief Executive Officer

 cc:
 Loeb & Loeb LLP

 Sichenzia Ross Ference Carmel LLP

CORRESP
 1
 filename1.htm

 April 11, 2025

 Via Edgar Transmission

 Ms. Rebekah Reed/Mr. Donald Field

 Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 Washington, D.C. 20549

 Re:

 Rich Sparkle Holdings Ltd (the " Company ")
 Draft Registration Statement on Form F-1
 Submitted September 13, 2024
 CIK No. 0002031688

 Dear Ms. Rebekah Reed/Mr. Donald Field

 As counsel for the Company
and on its behalf, this letter is being submitted in response to the letter dated March 14, 2024 from the Securities and Exchange Commission
(the " Commission ") in which the staff of the Commission (the " Staff ") commented on the above-referenced
Draft Registration Statement on Form F-1 (the " Form F-1 ").

 For the Staff's convenience, the Staff's
comment has been stated below in its entirety, with the Company's response set out immediately underneath such comment.

 Registration Statement on Form F-1 submitted
March 6, 2025

 Capitalization, page 57

 1. Please revise your description of ordinary shares to state
the correct number of ordinary shares issued and outstanding as adjusted assuming the over-allotment option is exercised in full. You
currently state this figure as 12,657,500. Given the disclosure in The Offering on page 20 that you have granted the underwriters the
option to purchase up to 187,500 additional ordinary shares, which would yield 12,687,500 shares outstanding if the over-allotment option
is exercised.

 Response: In response
to the Staff's comment, we have revised the relevant disclosure on the pages 57, 58 and 59.

 Industry, page 75

 2. To the extent available, please update the description of
your industry to include information as of a date more recent than 2023.

 Response: In response to the Staff's
comment, the information included in the Industry section has been updated to the extent available.

 Management

 Employment Agreements and Director Agreements,
page 100

 3. Please revise your disclosure for consistency with the material
terms of the executed employment agreements filed as Exhibits 10.1, 10.2, and 10.3 to the registration statement.

 Response: In response to
the Staff's comment, we have revised the relevant disclosure on page 100.

 Related Party Transactions, page 106

 4. Please revise footnote (1) to disclose the amount due to
the related party as of a more recent date. Refer to Item 7(B) of Form 20-F. In this regard, we note that the information is dated and
has only been provided as of October 31, 2024 and omits the information "up to the date of the document." Please revise as
applicable.

 Response: In response to
the Staff's comment, we have revised the relevant disclosure on page 106.

 Consolidated Financial Statements of Rich Sparkle
Holdings Limited and Subsidiaries

 Notes to Consolidated Financial Statements

 1. Organization and Business Description

 Reorganization, page F-7

 5. We note your disclosure here that, as part of the reorganization,
the 125 Ordinary Shares in issue will be "cancelled" and you will "reissue" 11,250,000 Ordinary Shares in aggregate
to your shareholders on a pro rata basis proportional to the shareholders' existing equity interests. This in substance appears
to be a 1:90,000 forward stock split. Please revise disclosure throughout your filing to describe this as such.

 Response: In response to the Staff's
comment, we have revised the relevant disclosure on the pages 61, 63, F-8 and II-2.

 6. Further, as this action is taken in contemplation of this
offering, please retrospectively restate presentation of ordinary shares throughout this document to present the equity section as it
will appear on effectiveness of this document. That is, you should present 11,250,000 ordinary shares on your balance sheet and use this
figure in calculating earnings per share. In this regard, we note you have appropriately used this share figure in The Offering disclosure
on page 20, in the Capitalization table on page 57, and in the calculation of Dilution on page 58.

 Response: In response to the Staff's
comment, we have revised the relevant disclosure on the pages 21, F-3, F-4, F-5 and F-22.

 7. As a related matter, in your next submission, please include
an Opinion, marked as a "draft" with a corresponding explanatory legend, that includes a dual date identifying the footnotes
that will be impacted should this portion of the Reorganization occur. The Opinion should contain the "draft" label and be
unsigned until such time as the forward stock split occurs.

 Response: The Audit firm will issue
a revised opinion if there's any change in the financials or footnotes.

 Please contact the undersigned
at (852) 3923 1188 you have any questions with respect to the responses contained in this letter.

 Sincerely,

 /s/ Lawrence Venick, Esq.

 Lawrence Venick, Esq.

 Direct Dial: +852 3923 1188

 Email: lvenick@loeb.com

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 14, 2025

Tsz Keung Chan
Chief Executive Officer
Rich Sparkle Holdings Ltd
Portion 2, 12th Floor, The Center
99 Queen s Road Central
Hong Kong

 Re: Rich Sparkle Holdings Ltd
 Registration Statement on Form F-1
 Filed March 6, 2025
 File No. 333-285592
Dear Tsz Keung Chan:

 We have reviewed your registration statement and have the following
comment(s).

 Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form F-1 filed March 6, 2025
Capitalization, page 57

1. Please revise your description of ordinary shares to state the correct
number of
 ordinary shares issued and outstanding as adjusted assuming the
over-allotment option
 is exercised in full. You currently state this figure as 12,657,500.
Given the disclosure
 in The Offering on page 20 that you have granted the underwriters the
option to
 purchase up to 187,500 additional ordinary shares, which would yield
12,687,500
 shares outstanding if the over-allotment option is exercised.
 March 14, 2025
Page 2
Industry, page 75

2. To the extent available, please update the description of your industry
to include
 information as of a date more recent than 2023.
Management
Employment Agreements and Director Agreements, page 100

3. Please revise your disclosure for consistency with the material terms of
the executed
 employment agreements filed as Exhibits 10.1, 10.2, and 10.3 to the
registration
 statement.
Related Party Transactions, page 106

4. Please revise footnote (1) to disclose the amount due to the related
party as of a more
 recent date. Refer to Item 7(B) of Form 20-F. In this regard, we note
that the
 information is dated and has only been provided as of October 31, 2024
and omits the
 information "up to the date of the document." Please revise as
applicable.
Consolidated Financial Statements of Rich Sparkle Holdings Limited and
Subsidiaries
Notes to Consolidated Financial Statements
1. Organization and Business Description
Reorganization, page F-7

5. We note your disclosure here that, as part of the reorganization, the
125 Ordinary
 Shares in issue will be "cancelled" and you will "reissue" 11,250,000
Ordinary Shares
 in aggregate to your shareholders on a pro rata basis proportional to
the shareholders
 existing equity interests. This in substance appears to be a 1:90,000
forward stock
 split. Please revise disclosure throughout your filing to describe this
as such.
6. Further, as this action is taken in contemplation of this offering,
please retrospectively
 restate presentation of ordinary shares throughout this document to
present the equity
 section as it will appear on effectiveness of this document. That is,
you should present
 11,250,000 ordinary shares on your balance sheet and use this figure in
calculating
 earnings per share. In this regard, we note you have appropriately used
this share
 figure in The Offering disclosure on page 20, in the Capitalization
table on page 57,
 and in the calculation of Dilution on page 58.
7. As a related matter, in your next submission, please include an Opinion,
marked as a
 "draft" with a corresponding explanatory legend, that includes a dual
date identifying
 the footnotes that will be impacted should this portion of the
Reorganization occur.
 The Opinion should contain the "draft" label and be unsigned until such
time as the
 forward stock split occurs.
 March 14, 2025
Page 3

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Amy Geddes at 202-551-3304 or Angela Lumley at
202-551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please contact Rebekah Reed at 202-551-5332 or Donald Field at
202-551-3680 with
any other questions.

 Sincerely,

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

November 19, 2024
Tsz Keung Chan
Chief Executive Officer
Rich Sparkle Holdings Ltd
Portion 2, 12th Floor, The Center
99 Queen’s Road Central
Hong Kong
Re:Rich Sparkle Holdings Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted October 30, 2024
CIK No. 0002031688
Dear Tsz Keung Chan:
            We have reviewed your amended draft registration statement and have the following
comment(s).
            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 October 7, 2024 letter.
Amendment No. 1 to Draft Registration Statement on Form F-1 submitted October 30, 2024
Cover Page
1.We note your response to prior comment 2 and added disclosure that you "are subject
to certain legal and operational associated with our operating entity being based in
Hong Kong..." Please revise this sentence to state that you are subject to certain legal
and operational  risks associated with your operations in Hong Kong.
Please further enhance your disclosure regarding transfer of funds within your
organization to explain how cash is transferred from the holding company to your
subsidiaries. In response to prior comment 3, you have revised to state that Rich 2.

November 19, 2024
Page 2
Sparkle "relies on dividends and other distributions on equity" from its operating
subsidiary, but it remains unclear how funds would be transferred in the other
direction. Provide this disclosure in the discussion of cash transfers in the prospectus
summary as well.
Prospectus Summary
Permission Required From Hong Kong and Chinese Authorities, page 13
3.We note your response to prior comment 11 and reissue. Please revise to clearly
indicate, if true, that you have relied upon opinions of PRC and Hong Kong counsel
with respect to each conclusion regarding permissions and approvals from PRC and
Hong Kong regulatory authorities. In this regard, you continue to use ambiguous
language, such as "[a]s confirmed by our PRC Counsel," "as further advised by our
PRC Counsel," and "[a]s confirmed by David Fong & Co," rather than clear indication
that you have received opinions from such counsel.
Management
Compensation of Directors and Executive Officers, page 107
4.Please update your executive officer and director compensation information for your
fiscal year ended September 30, 2024. Refer to Item 6.B of Form 20-F.
Related Party Transactions, page 109
5.We reissue prior comment 20. Revise to provide the information called for by Item
7.B of Form 20-F with respect to each related party transaction required to be
disclosed in this section. In this regard, you continue to disclose a related party
balance as of certain dates without discussing the underlying “advances from the
related company” that resulted in such balance. Additionally, please disclose the
outstanding amount(s) due to Superb Prospect Group Ltd. as of the most recent
practicable date.
General
6.We note your response to prior comment 23, particularly that the outstanding
25 Series A preferred shares held by FCGM Strategic Investment Pte. Ltd. will
automatically convert into ordinary shares prior to consummation of the IPO pursuant
to terms of the subscription agreement dated June 26, 2024. Please further clarify
whether the class of Series A preferred shares will remain authorized pursuant to your
governing documents (i.e. Second Amended and Restated Memorandum and Articles
of Association) such that additional shares of the class may be issued by the
company at any time, even if no Series A preferred shares are outstanding at the time
of the IPO. In this regard, your condensed consolidated balance sheets as of March 31,
2024 indicate that 25,000 Series A preferred shares are authorized under your
governing documents. To the extent that your governing documents to be effective
following the IPO will continue to authorize the issuance of preferred shares, revise to
briefly describe such dual- or multi-class structure and the different authorized classes
of stock in the prospectus cover page, summary, risk factors, and capitalization
sections. Explain the nature of any disparate voting or other material rights associated
with the classes.

November 19, 2024
Page 3
            Please contact Amy Geddes at 202-551-3304 or Angela Lumley at 202-551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please contact Rebekah Reed at 202-551-5332 or Donald Field at 202-551-3680 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Lawrence Venick

October 7, 2024
Tsz Keung Chan
Chief Executive Officer
Rich Sparkle Holdings Ltd
Portion 2, 12th Floor, The Center
99 Queen’s Road Central
Hong Kong
Re:Rich Sparkle Holdings Ltd
Draft Registration Statement on Form F-1
Submitted September 13, 2024
CIK No. 0002031688
Dear Tsz Keung Chan:
            We have reviewed your draft registration statement and have the following
comment(s).
            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.
Draft Registration Statement on Form F-1 submitted September 13, 2024
Cover Page
1.Please revise to clearly acknowledge that Chinese regulatory authorities could
disallow your holding company structure, which would likely result in a material
change in your operations and/or a material change in the value of the securities you
are registering for sale, including that it could cause the value of such securities to
significantly decline or become worthless.
Please revise to clearly state that there are legal and operational risks associated with
being based in or having the majority of the company’s operations in Hong Kong, and
make clear whether these risks could result in a material change in your operations 2.

October 7, 2024
Page 2
and/or the value of the securities you are registering for sale or could significantly
limit or completely hinder your ability to offer or continue to offer securities to
investors and cause the value of such securities to significantly decline or be
worthless. Additionally, please revise to include additional cross-references to
individual risk factors related to your operations in Hong Kong.
3.Revise to provide a more detailed description of how cash is transferred through your
organization. Additionally, please state whether there have been any transfers,
dividends, or distributions made to date from the holding company or its subsidiaries
to investors, as we note that your disclosure speaks only to transfers of cash,
dividends, and distributions between the holding company and subsidiaries. Lastly,
please revise your disclosure regarding transfers of cash to cover up to the date of the
prospectus, as you have done for “dividends and distributions.”
4.Disclose on the cover page how regulatory actions related to data security or anti-
monopoly concerns in Hong Kong have or may impact the company’s ability to
conduct its business, accept foreign investment or list on a U.S. or foreign exchange.
In this regard, we note that your disclosure focuses only on PRC-specific regulations
without also addressing Hong Kong-specific regulations.
Conventions that Apply to this Prospectus, page ii
5.We note that your definition of China and the PRC excludes Hong Kong and Macau.
Please clarify, either in the definition itself or in an appropriate discussion of legal and
operational risks, that the legal and operational risks associated with operating in
China also apply to your operations in Hong Kong.
Prospectus Summary, page 1
6.Provide a clear description of how cash is transferred through your organization.
Quantify any cash flows and transfers of other assets by type that have occurred
between the holding company and its subsidiaries, and direction of transfer. Quantify
any dividends or distributions that a subsidiary has made to the holding company and
which entity made such transfer, and their tax consequences. Similarly quantify
dividends or distributions made to U.S. investors, the source, and their tax
consequences. Your disclosure should make clear if no transfers, dividends, or
distributions have been made to date. Describe any restrictions on foreign exchange
and your ability to transfer cash between entities, across borders, and to U.S.
investors. Describe any restrictions and limitations on your ability to distribute
earnings from the company, including your subsidiaries, to the parent company and
U.S. investors.
Corporate History and Structure, page 2
7.Please revise the diagram of your corporate structure to identify clearly the entity in
which investors are purchasing their interest and the entity(ies) in which the
company’s operations are conducted.  Consider adding footnote or narrative
disclosure as applicable.

October 7, 2024
Page 3
Summary of Risk Factors
Risks Relating to Doing Business in Hong Kong and the PRC, page 3
8.Where you state that the PRC government “may intervene or influence [y]our
operations,” please revise to acknowledge further that such intervention or influence
may happen at any time. Make conforming revisions to the risk factor at page 15.
Additionally, please revise so that each summary risk factor in this section includes a
cross-reference to the relevant individual detailed risk factor, including page number.
9.State here and in the risk factors, as you have on the cover page, that to the extent cash
or assets in the business is in Hong Kong or a Hong Kong entity, the funds or assets
may not be available to fund operations or for other use outside of Hong Kong due to
interventions in or the imposition of restrictions and limitations on the ability of you
or your subsidiaries by the PRC government to transfer cash or assets.
Permission Required From Hong Kong and Chinese Authorities, page 9
10.Please revise to affirmatively identify the “requisite permissions or approvals from the
Hong Kong authorities” that you and your subsidiaries must obtain to operate your
business, and where you state that all such permissions and approvals have been
received, please also state whether any permissions or approvals have been denied.
11.Please revise to clarify whether you have relied upon an opinion of counsel with
respect to each of your conclusions regarding permissions and approvals from Hong
Kong and PRC authorities to operate your business and offer securities to investors.
For example, you state that you have been “advised by” your Hong Kong counsel
rather than clear indication of an opinion. Additionally, it appears that you are not
relying on an opinion of counsel regarding your conclusion that you and your
subsidiaries do not need any permissions and approvals from PRC authorities,
including the Cyberspace Administration of China (CAC) or the China Securities
Regulatory Commission (CSRC). If true, state as much and explain why such an
opinion was not obtained.
Risk Factors
Risks Related to Doing Business in Hong Kong and the PRC, page 15
12.In light of recent events indicating greater oversight by the CAC over data security,
particularly for companies seeking to list on a foreign exchange, please revise your
risk factor disclosure to explain how this oversight impacts your business and your
offering and to what extent you believe that you are compliant with the regulations or
policies that have been issued by the CAC to date. Additionally, include risk factor
disclosure explaining whether there are laws or regulations in Hong Kong that result
in oversight over data security, how this oversight impacts the company’s business
and the offering, and to what extent the company believes that it is compliant with the
regulations or policies that have been issued.
Industry, page 68
13.We note your disclosure that this section contains information from an industry report
commissioned by you and prepared by CIC. Please file as an exhibit to the registration
statement the consent of CIC required by Rule 436 under the Securities Act.

October 7, 2024
Page 4
Business
Overview, page 82
14.Please provide additional detail regarding the "provision of co-working space" that
you describe as a service offered to your customers. Clarify where such space is
located and whether you own or lease such space, and explain how this service fits
into the revenue categories of "financial printing services," "advisory services," and
"other services" discussed at page 58.
Our Competitive Strengths, page 83
15.Where you discuss your "broad and diverse customer base," please contextualize your
statement that you have "over 160 customers" by disclosing the relevant measurement
date or period for such amount. For example, explain whether this is the number of
customers you have had since formation, during a particular financial period, or
something else. Provide similar disclosure where you identify "large customer base"
as a competitive strength at page 1 of the prospectus summary.
Growth Strategies, page 84
16.Please discuss the costs and timing associated with the growth strategies identified in
this section. For example, clarify the anticipated costs associated with "procur[ing]
[AI technologies] from third-party information technologies vendors" and
"recruit[ing] staff to support our expansion," and disclose when you expect to
commence providing financial printing services in the United States. Ensure that any
risks associated with these growth strategies are properly addressed.
Operation, page 86
17.Please elaborate on the role of third party subcontractors within your business
operations and the extent to which you rely on them to provide services to customers.
In this regard, we note your disclosure at page 27 that if suppliers "are unavailable to
provide services to us...our operations, business, reputation, and profitability may be
adversely affected," as well as the fact that "subcontracting fee" comprised 39.5% and
45.1% of cost of services for the six months ended March 31, 2024 and year ended
September 30, 2023, respectively. Disclose whether you have any standing
contractual arrangement with the supplier that accounted for over 10% of total cost of
revenue for the six months ended March 31, 2024 and if so, disclose the material
details of such arrangement and file any related agreements as exhibits, or explain
why you are not required to do so. Refer to Item 601(b)(10) of Regulation S-K.
Management
Directors and Executive Officers, page 91
18.Expand your biographical disclosure for Ka Wo Ng to provide additional information
regarding his experience and qualifications, including his business experience,
functions, and areas of experience in the company and any principal business
activities performed outside the company. Refer to Item 6.A of Form 20-F.

October 7, 2024
Page 5
Employment Agreements and Director Agreements, page 92
19.You state that you "will enter" into employment agreements with each of your
executive officers, but also that these individuals "have agreed" to serve as executive
officers for a period of three years. Please clarify whether these employment
agreements have been entered into, and file them as exhibits to the registration
statement. Refer to Item 601(b)(10)(iii) of Regulation S-K.
Related Party Transactions, page 98
20.Please revise to provide the information called for by Item 7.B of Form 20-F with
respect to each related party transaction required to be disclosed in this section. In this
regard, we note that you have disclosed a related party balance as of certain dates
without discussing the underlying loans and/or other transactions (i.e., the "advances
from the related company") that resulted in such balance. Please also ensure that any
outstanding amount due to Superb Prospect Group Ltd. is also disclosed as of the
most recent practicable date.
Consolidated Financial Statements
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Revenue Recognition, page F-11
21.We note from your disclosure on Note 14 that you earn revenue from Advisory
Services and Others. Please revise your disclosure to state your recognition policy for
each of these revenue streams.
22.We note from your disclosure on page 87 that you provide services such as
typesetting, translating, designing, printing and advisory services. Please tell us
whether these services are always provided together as a unit, or if these services can
be or have been provided on an individual basis. In addition, we note that many of
these services are fulfilled by a third party. Please provide us with your "principle vs.
agent" analysis for each of your revenue streams. Please refer to the guidance in ASC
606-10-50-12(c) and ASC 606-10-55-36 through 40.
General
23.We note from your disclosure at pages 52 and F-7 that 25 Series A preferred shares
were issued to FCGM Strategic Investment Pte. Ltd. in July 2024, although it appears
that these may be converted into ordinary shares prior to the consummation of the
offering. If you will have an authorized dual- or multi-class capital structure at the
time of the IPO, please revise to briefly describe such structure and the different
authorized classes of stock in the prospectus cover page, summary, risk factors, and
capitalization sections. Explain the nature of any disparate voting or other material
rights associated with the classes.
We note that a key growth strategy and use of offering proceeds is incorporation of
generative artificial intelligence features into your products and services. Please revise
to include a definition of "artificial intelligence" within the context of your business,
and include an appropriate risk factor addressing the material risks that use of
generative artificial intelligence pose to your business, operations, and financial 24.

October 7, 2024
Page 6
condition, as appropriate. Additionally, where you discuss your artificial intelligence
growth strategy at pages 53 and 84, elaborate on your disclosure that these
technologies will allow you to "generate content that aligns with...regulatory
standards," "detect and correct errors in financial documents with high precision," and
"ensur[e] compliance with regulatory guidelines," which may be read to imply that
artificial intelligence will result in expansion of your services beyond "typesetting,
proofreading, translation, design, and printing." Please clarify whether, for example,
you will assume increased responsibility for the substantive content of your clients'
regulatory filings upon utilizing these tools.
25.Please provide us with supplemental copies of all written communications, as defined
in Rule 405 under the Securities Act, that you, or anyone authorized to do so on your
behalf, have presented or expect to present to potential investors in reliance on Section
5(d) of the Securities Act. Please contact the staff member associated with the review
of this filing to discuss how to submit the materials, if any, to us for our review.
            Please contact Amy Geddes at 202-551-3304 or Angela Lumley at 202-551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please contact Rebekah Reed at 202-551-5332 or Donald Field at 202-551-3680 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Lawrence Venick