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United States securities and exchange commission logo
April 11, 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. 3 to
Draft Registration Statement on Form F-1
Submitted April 9,
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.
Amendment No. 3 to Draft Registration Statement on Form F-1
Consolidated Financial Statements
Note 31. Share Capital of the Company / Combined Capital of
Subsidiaries, page F-51
1. Please provide a
reconciliation of the number of shares outstanding at the beginning and at
the end of each period
presented. Refer to paragraph 79 of IAS 1. Also, revise your
disclosures to
reconcile the statement on page F-52 that shares held under the share award
scheme were presented
as treasury shares (i.e., issued, but not outstanding) and your
statement on page 8
that the 61,933,000 ordinary shares issued to the ESOP Platforms are
included in ordinary
shares issued and outstanding as of the date of this prospectus. Also,
tell us and disclose
the current status of the shares held under the share award scheme,
including whether they
have been allocated to participants, and if so, disclose the
Cong Qu
SUPER HI INTERNATIONAL HOLDING LTD.
April 11, 2024
Page 2
allocation date(s) and terms, along with the share-based compensation
amount to be
recorded and the period(s) over which it will be recorded.
Please contact Patrick Kuhn at 202-551-3308 or Rufus Decker at
202-551-3769 with any
questions.
Sincerely,
FirstName LastNameCong Qu
Division of Corporation Finance
Comapany NameSUPER HI INTERNATIONAL HOLDING LTD.
Office of Trade & Services
April 11, 2024 Page 2
cc: Dr. Mengyu Lu
FirstName LastName