October 23, 2024

Via Edgar Transmission

Mr. Thomas Jones / Jay Ingram

Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

Washington, D.C. 20549

Dear Mr. Jones / Mr. Ingram:

As counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated October 22, 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 filed October 4, 2024

Certain Relationships and Related Party Transactions, page 98

Response: We respectfully advise the Staff that we have revised the disclosure on page 98 to address the above.

General

Response: We respectfully advise the Staff that we have revised the disclosure on page Alt -23 to address the above. The Company confirms its understanding that the retention by a selling shareholder of an underwriter would constitute material change to the plan of distribution requiring a post-effective amendment.

* * * 

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

Sincerely,