become WEH shareholders, and the existing WEH shareholders would become NUSA shareholders.  After considering the clarifications submitted by NUSA, the SEC identified ambiguity in various reasonings. For

shares are held by JAS and the other 20 percent are held by Acumen Co., Ltd. (“ACU”) which is another subsidiary of JAS. JAS, ACeS Regional Services Co., Ltd. and T.J.P. Engineering Co., Ltd., including Mr

subsidiary of JAS, whereby 80 percent of its shares are held by JAS, and another 20 percent are held by Acumen Co., Ltd. (“ACU”) which is another subsidiary of JAS. JAS, ACeS Regional Services Co., Ltd., and

. Engineering Co., Ltd. (“TJP”) is a subsidiary of JAS, whereby 80 percent of its shares are held by JAS, and another 20 percent are held by Acumen Co., Ltd. (“ACU”) which is another subsidiary of JAS. JAS, ACeS

. Engineering Co., Ltd. (“TJP”) is a subsidiary of JAS, whereby 80 percent of its shares are held by JAS and the other 20 percent are held by Acumen Co., Ltd. (“ACU”) which is another subsidiary of JAS. JAS, ACeS