CORRESP 1 filename1.htm

 

March 28, 2023

 

VIA EDGAR

 

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington, D.C., 20549

 

Attention: Ms. Andi Carpenter
  Mr. Andrew Blume
  Mr. Patrick Fullem
  Mr. Jay Ingram

 

Re: Multi Ways Holdings Limited
  Registration Statement on Form F-1, as amended (File No. 333-269641)
  Request for Acceleration of Effectiveness

 

Ladies and Gentlemen:

 

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), we, the underwriter (the “Underwriter”), hereby join in the request of Multi Ways Holdings Limited (the “Registrant”), for the acceleration of the effective date of the Registrant’s Registration Statement on Form F-1 (File No. 333-269641) (as amended, the “Registration Statement”), relating to a public offering of shares of the Registrant’s ordinary shares, US$0.00025 par value, so that the Registration Statement may be declared effective on March 30, 2023, at 4.30 p.m. Eastern Time, or as soon thereafter as practicable. The undersigned, as the Underwriter, confirms that it is aware of its obligations under the Securities Act.

 

Pursuant to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter, who is reasonably anticipated to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

 

The undersigned confirms that it has complied with and will continue to comply with, and it has been informed or will be informed by participating dealers that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the above-referenced issue.

 

  Very truly yours,
     
  SPARTAN CAPITAL SECURITIES LLC
     
    /s/ Kim Monchik
  Name: Kim Monchik
  Title: Chief Administrative Officer