Graubard Miller The Chrysler Building 405 Lexington Avenue New York, N.Y. 10174-1901 (212) 818-8800 |
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facsimile | direct dial number | |||
(212) 818-8881 | (212) 818-8638 | |||
email address | ||||
jgallant@graubard.com | ||||
June 15, 2017
VIA EDGAR
Ms. Pamela Long
Assistant Director
Office of Manufacturing and Construction
Securities and Exchange Commission
Mail Stop 7010
100 F Street, NE
Washington, DC 20549
Re: | Plastec Technologies, Ltd. |
Post-effective Amendment No. 5 to Registration Statement on Form F-1
Filed May 30, 2017
File No. 333-185212
Dear Ms. Long:
On behalf of Plastec Technologies, Ltd. (the “Company”), we respond as follows to the Staff’s comment letter, dated June 15, 2017, relating to the above-captioned Registration Statement. Please note that for the Staff’s convenience, we have recited each of the Staff’s comments and provided the Company’s response to each comment immediately thereafter.
General
1. | The post-effective amendment filed on May 30, 2017 includes audited financial |
statements for the year ended December 31, 2016. To satisfy the updating
requirements of Section 10(a)(3) of the Securities Act, the post-effective amendment
was required to be filed on or before April 30, 2017. Since Section 5(b) of the
Securities Act, together with Section 2(a)(10)(a) of the Securities Act, requires that a
prospectus meeting the requirements of Section 10(a) be delivered before or at the
same time with a confirmation of sale of a security, please advise us whether offers or sales were made under the registration statement without a valid Section 10(a) prospectus. We may have further comment after reviewing your response.
We wish to advise the Staff that no offers or sales were made under the Registration Statement after April 30, 2017 (and therefore without a valid Section 10(a) prospectus).
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If you have any questions, please do not hesitate to contact me at the above telephone and facsimile numbers.
Sincerely,
/s/ Jeffrey M. Gallant
Jeffrey M. Gallant
cc: Ho Leung Ning