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United States securities and exchange commission logo
April 2, 2024
Cong Qu
Financial Director
SUPER HI INTERNATIONAL HOLDING LTD.
1 Paya Lebar Link, #09-04
PLQ 1 Paya Lebar Quarter
Singapore 408533
Re: SUPER HI
INTERNATIONAL HOLDING LTD.
Amendment No. 2 to
Draft Registration Statement on Form F-1
Submitted March 8,
2024
CIK No. 0001995306
Dear Cong Qu:
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
February 23, 2024 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1
General
1. We note your response
to prior comment 6 and reissue it in part. Please further revise the
relevant risk factor on
page 37 as well as the "Enforceability of Civil Liabilities" section
to clearly identify the
executive officer who resides in mainland China.
Cong Qu
FirstName
SUPER HI LastNameCong Qu HOLDING LTD.
INTERNATIONAL
Comapany
April NameSUPER HI INTERNATIONAL HOLDING LTD.
2, 2024
April 22, 2024 Page 2
Page
FirstName LastName
Please contact Rucha Pandit at 202-551-6022 or Mara Ransom at
202-551-3264 with
any questions.
Sincerely,
Division of Corporation
Finance
Office of Trade &
Services
cc: Dr. Mengyu Lu