United States securities and exchange commission logo
November 24, 2023
Mikheil Lomtadze
Chief Executive Officer
Joint Stock Co Kaspi.kz
154A Nauryzbay Batyr Street
Almaty, 050013, Kazakhstan
Re: Joint Stock Co
Kaspi.kz
Amendment No. 2 to
Draft Registration Statement on Form F-1
Submitted November
9, 2023
CIK No. 0001985487
Dear Mikheil Lomtadze:
We have reviewed your amended draft registration statement and have
the following
comment.
Please respond to this letter by providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. 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 the information you provide in response to this
letter and your amended
draft registration statement or filed registration statement, we may
have additional comments.
Amendment No. 1 to Draft Registration Statement on Form F-1
General
1. Please supplementally
provide us with the Level III ADS Deposit Agreement. Please also
confirm that you will
file the March 28, 2019 GDR Deposit Agreement with your Form F-
6. Please see Item 3(c)
of Form F-6.
Mikheil Lomtadze
FirstName
Joint StockLastNameMikheil Lomtadze
Co Kaspi.kz
Comapany 24,
November NameJoint
2023 Stock Co Kaspi.kz
November
Page 2 24, 2023 Page 2
FirstName LastName
Please contact Ryan Rohn at 202-551-3739 or Stephen Krikorian at
202-551-3488 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Aliya Ishmukhamedova at 202-551-7519 or Jan Woo at 202-551-3453 with
any other
questions.
Sincerely,
Division of Corporation
Finance
Office of Technology
cc: Nicholas P. Pellicani