CTRL GROUP Ltd — Regulatory Filings 2024

Dec 30, 2024

CORRESP 1 filename1.htm

R.F. Lafferty & Co., Inc.

Via EDGAR

December 30, 2024

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

Attention:
Lyn Shenk Brian Fetterolf Mara Ransom

Re:
Registration Statement on Form F-1, as amended
Initially Filed on March 15, 2024
File No. 333-277979

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, R.F. Lafferty & Co., Inc., as the representative of underwriters, hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it will become effective at 2:00 p.m., Eastern Time, on Tuesday, December 31, 2024 , or as soon thereafter as practicable.

Pursuant to Rule 460 under the Securities Act, we wish to advise you that we will take reasonable steps to secure adequate distribution of the preliminary prospectus to underwriters, dealers, institutions and others prior to the requested effective time of the Registration Statement.

We have been advised by the prospective underwriters that they have complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

Very truly yours,

R.F. Lafferty & Co., Inc.
By:	/s/ Robert Hackel
Name:	Robert Hackel
Title:	Chief Operating Officer