United States securities and exchange commission logo
April 4, 2024
Raju Vegesna
Chief Executive Officer
Sify Technologies Limited
TIDEL Park, 2nd Floor
4, Rajiv Gandhi Salai
Taramani, Chennai 600 113 India
Re: Sify Technologies
Limited
Registration
Statement on Form F-1
Filed March 21,
2024
File No. 333-278152
Dear Raju Vegesna:
We have conducted a limited review of your registration statement
and have the
following comment.
Please respond to this letter by amending your registration
statement and providing the
requested information. 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 any amendment to your registration statement and
the information you
provide in response to this letter, we may have additional comments.
Form F-1 filed March 21, 2024
Cover Page
1. We note your cover page
disclosure that entities affiliated with your CEO, Chairman and
Managing Director, Mr.
Raju Vegesna, beneficially own approximately 84.11% of your
outstanding equity
shares. Please revise to disclose, on the cover page and in the
prospectus summary,
whether you will be a controlled company as defined under the
relevant Nasdaq listing
rules and, if so, whether you intend to rely on "controlled
company" exemptions. To
the extent you will be considered a "controlled company",
please include risk
factor disclosure that discusses the effect, risks and uncertainties of
being designated a
controlled company, including but not limited to, the result that you
may elect not to comply
with certain corporate governance requirements.
Raju Vegesna
FirstName LastNameRaju
Sify Technologies LimitedVegesna
Comapany
April NameSify Technologies Limited
4, 2024
April 24, 2024 Page 2
Page
FirstName LastName
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
Please contact Mariam Mansaray at 202-551-6356 or Mitchell Austin at
202-551-3574
with any other questions.
Sincerely,
Division of
Corporation Finance
Office of Technology
cc: Greg Harrington