0001493152-24-033830.txt : 20240924 0001493152-24-033830.hdr.sgml : 20240924 20240826093323 ACCESSION NUMBER: 0001493152-24-033830 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20240826 FILER: COMPANY DATA: COMPANY CONFORMED NAME: JBDI Holdings Ltd CENTRAL INDEX KEY: 0001964314 STANDARD INDUSTRIAL CLASSIFICATION: METAL SHIPPING BARRELS, DRUMS, KEGS & PAILS [3412] ORGANIZATION NAME: 04 Manufacturing IRS NUMBER: 000000000 STATE OF INCORPORATION: E9 FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 34 GUL CRESCENT CITY: SINGAPORE STATE: U0 ZIP: 629538 BUSINESS PHONE: 65 6861 4150 MAIL ADDRESS: STREET 1: 34 GUL CRESCENT CITY: SINGAPORE STATE: U0 ZIP: 629538 CORRESP 1 filename1.htm

August 26, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

Attn: Mr. Patrick Fullem

Re:

JBDI Holdings Limited

Registration Statement on Form F-1, as amended (File No. 333-276945)

Request for Acceleration of Effectiveness

Dear Mr. Fullem:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), we, the underwriter (the “Underwriter”), hereby join in the request of JBDI Holdings Limited (the “Registrant”), for the acceleration of the effective date of the Registrant’s Registration Statement on Form F-1 (File No. 333-276945) (as amended, the “Registration Statement”), relating to a public offering of shares of the Registrant’s ordinary shares, US$0.0005 par value, so that the Registration Statement may be declared effective on August 26, 2024, at 2:00 p.m. Eastern Time, or as soon thereafter as practicable. The undersigned, as the Underwriter, confirms that it is aware of its obligations under the Securities Act.

Pursuant to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter, who is reasonably anticipated to be invited 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 with and will continue to comply with, and it has been informed or will be informed by participating dealers that they have complied with 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,

	Wilson-Davis & Co., Inc.

		/s/ Robert McBey
	Name:	Robert McBey
	Title:	Chief Executive Officer