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United States securities and exchange commission logo
May 1, 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.
Registration
Statement on Form F-1
Filed April 26,
2024
File No. 333-278940
Dear Cong Qu:
We have reviewed your
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.
Registration Statement on Form F-1
Super Hi - At a Glance
1. As requested in comment
3 of our January 12, 2024 letter, please present income from
operation margin when
restaurant level operating margin is presented. Also disclose
where the
reconciliation between the IFRS amount and non-IFRS amount is presented.
Refer to Item
10(e)(1)(i) of Regulation S-K.
Cong Qu
FirstName
SUPER HI LastNameCong Qu HOLDING LTD.
INTERNATIONAL
Comapany
May 1, 2024NameSUPER HI INTERNATIONAL HOLDING LTD.
May 1,
Page 2 2024 Page 2
FirstName LastName
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
Please contact Patrick Kuhn at 202-551-3308 or Rufus Decker at
202-551-3769 with any
questions.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services
cc: Ming Kong