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United States securities and exchange commission logo
May 14, 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. 1 to
Registration Statement on Form F-1
Filed May 13, 2024
File No. 333-278940
Dear Cong Qu:
We have reviewed your amended registration statement and have the
following
comment(s).
Please respond to this letter by amending your registration
statement and providing the
requested information. 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 any amendment to your registration statement and
the information you
provide in response to this letter, we may have additional comments.
Amendment No. 1 to Registration Statement on Form F-1
Recent Developments, page 14
1. In your presentation of
unaudited consolidated statement of profit or loss data and selected
operating data for the
three months ended March 31, 2024, you direct readers to
Management s
Discussion and Analysis of Financial Condition and Results of
Operations for
information regarding trends and other factors, including seasonality, that
may influence your
results of operations and for recent quarterly operating results.
However, you have not
included a discussion of these results under "Management's
Discussion and Analysis
of Financial Condition and Results of Operations" or in your
financial statements.
Revise to clarify, if true, that these results are preliminary in nature
and to state that your
financial and closing procedures for the period ended March 31,
2024 have not yet been
completed. Disclose when you anticipate your financial statements
for the quarter ending
March 31, 2024 will be available. Revise to provide qualitative
Cong Qu
SUPER HI INTERNATIONAL HOLDING LTD.
May 14, 2024
Page 2
disclosure about how such results impact your trends disclosure provided
elsewhere.
Alternatively, if these results are not preliminary in nature, revise to
include a discussion
of such results in your "Management's Discussion and Analysis of
Financial Condition
and Results of Operations" and update your financial statements.
Please contact Rucha Pandit at 202-551-6022 or Mara Ransom at
202-551-3264 with
any questions.
Sincerely,
FirstName LastNameCong Qu
Division of Corporation Finance
Comapany NameSUPER HI INTERNATIONAL HOLDING LTD.
Office of Trade & Services
May 14, 2024 Page 2
cc: Ming Kong
FirstName LastName