0001493152-24-038348.txt : 20241030 0001493152-24-038348.hdr.sgml : 20241030 20240926170621 ACCESSION NUMBER: 0001493152-24-038348 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20240926 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SAG Holdings Ltd CENTRAL INDEX KEY: 0001933951 STANDARD INDUSTRIAL CLASSIFICATION: WHOLESALE-MOTOR VEHICLES & MOTOR VEHICLE PARTS & SUPPLIES [5010] ORGANIZATION NAME: 07 Trade & Services IRS NUMBER: 000000000 STATE OF INCORPORATION: E9 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 14 ANG MO KIO STREET 63 CITY: SINGAPORE STATE: U0 ZIP: 569116 BUSINESS PHONE: 65 6383 7540 MAIL ADDRESS: STREET 1: 14 ANG MO KIO STREET 63 CITY: SINGAPORE STATE: U0 ZIP: 569116 CORRESP 1 filename1.htm

 

SAG Holdings Limited

14 Ang Mo Kio Street 63

Singapore 569116

 

September 26, 2024

 

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Washington, D.C. 20549

Attention: Scott Anderegg

 

  Re: SAG Holdings Limited
    Amendment No. 20 to Registration Statement on Form F-1
    File No. 333-267771

 

Ladies and Gentlemen:

 

SAG Holdings Limited (the “Company”) has submitted the Company’s Amendment No. 21 to Registration Statement on Form F-1 today to respond to the comment of the staff (the “Staff”) of the Securities and Exchange Commission contained in its letter dated September 26, 2024 with respect to the Company’s Registration Statement, as noted above. The text of the Staff’s comment is set forth below, followed by the Company’s response.

 

Amendment No. 20 to Registration Statement on Form F-1

General

 

  1. Please refer to Exhibit 5.1. Please have company counsel revise the legal opinion to cover the registered public offering and resale offering. In this regard, we note that most recent legal opinion dated June 14, 2023 is dated and doesn’t cover the current offerings and specifically the resale offerings. Please revise as applicable.

 

We have filed an updated Exhibit 5.1 that covers the current offerings and resale offerings.

 

If you have any questions regarding this response, please direct them to our counsel David Ficksman at 310-789-1290 or dficksman@troygould.com or Joilene Wood at 415-305-4651 or jwood@troygould.com.

 

  Sincerely,
   
  SAG Holdings Limited
   
    /s/ Jimmy Neo
  By: Jimmy Neo
    Chief Executive Officer & Executive Director

 

cc: David L. Ficksman
  R. Joilene Wood