PERFECT MOMENT LTD.
307 Canalot Studios
222 Kensal Road
London W10 5BN
United Kingdom
February 5, 2024
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Manufacturing
100 F Street, N.E.
Washington, D.C. 20549
Attention: | Heather Clark |
| Kevin Stertzel |
| Jennifer Angelini |
| Jay Ingram |
RE: | Perfect Moment Ltd. |
| Registration Statement on Form S-1, as amended |
| File No. 333-274913 |
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Perfect Moment Ltd. (the “Registrant”) hereby requests that the U.S. Securities and Exchange Commission (the “Commission”) take appropriate action to cause the above-referenced registration statement (the “Registration Statement”) to become effective on February 7, 2024 at 5:00 p.m., Eastern Time, or as soon thereafter as is practicable, or at such later time as the Registrant may orally request via telephone call to the staff of the Commission. The Registrant hereby authorizes Mitchell Silberberg & Knupp LLP, counsel to the Registrant, to orally modify or withdraw this request for acceleration.
Once the Registration Statement has been declared effective, please orally confirm that event with Blake Baron of Mitchell Silberberg & Knupp LLP, counsel to the Registrant, at (917) 546-7709, or in his absence, Nimish Patel at (310) 312-3102.
[Signature Page Follows]
| Sincerely, |
| |
| PERFECT MOMENT LTD. |
| |
| By: | /s/ Mark Buckley |
| | Mark Buckley |
| | Chief Executive Officer |
Cc: | Nimish Patel, Mitchell Silberberg & Knupp LLP |
| Blake Baron, Mitchell Silberberg & Knupp LLP |