SEC Comment Letter 0000000000-23-002747 to SHL TELEMEDICINE LTD (SHLT) (CIK 0001166834) (SHMLF)
SHL TELEMEDICINE LTD (SHLT) (CIK 0001166834)
Date: March 20, 2023 · CIK: 0001166834 · Accession: 0000000000-23-002747
AI Filing Summary & Sentiment
File numbers found in text: 001-41641
Letter
United States securities and exchange commission logo March 20, 2023 Erez Nachtomy Chief Executive Officer SHL Telemedicine Ltd. 90 Yigal Alon Street Tel Aviv 67891, Israel Re:SHL Telemedicine Ltd. Registration Statement on Form 20FR12B Filed March 8, 2023 File No. 001-41641 Dear Erez Nachtomy: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response and any amendment you may file in response to this comment, we may have additional comments. Registration Statement on Form 20-F, filed March 8, 2023 Overview, page 23 1.We note your response to our prior comment number 1 and your revision to page 26, where you state that you "have successfully proven through several clinical studies that users of the SHL’s mobile 12 lead ECG technology benefit from a lower risk of being re- hospitalized during the first 30 days and a lower risk of mortality during the first year following discharge from the hospital after a heart attack and an improvement in quality of life." As efficacy determinations are solely within the FDA's authority, please revise these references to SHL technology's proven efficacy. You may provide relevant quantitative data from the studies to support your claims. 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.
FirstName LastNameErez Nachtomy Comapany NameSHL Telemedicine Ltd. March 20, 2023 Page 2 FirstName LastName Erez Nachtomy SHL Telemedicine Ltd. March 20, 2023 Page 2 You may contact Benjamin Richie at 202-551-7857 or Lauren Nguyen at 202-551-3642 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc: Scott R. Saks
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United States securities and exchange commission logo
March 20, 2023
Erez Nachtomy
Chief Executive Officer
SHL Telemedicine Ltd.
90 Yigal Alon Street
Tel Aviv 67891, Israel
Re:SHL Telemedicine Ltd.
Registration Statement on Form 20FR12B
Filed March 8, 2023
File No. 001-41641
Dear Erez Nachtomy:
We have reviewed your filing and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response and any amendment you may file in response to
this comment, we may have additional comments.
Registration Statement on Form 20-F, filed March 8, 2023
Overview, page 23
1.We note your response to our prior comment number 1 and your revision to page 26,
where you state that you "have successfully proven through several clinical studies that
users of the SHL’s mobile 12 lead ECG technology benefit from a lower risk of being re-
hospitalized during the first 30 days and a lower risk of mortality during the first year
following discharge from the hospital after a heart attack and an improvement in quality
of life." As efficacy determinations are solely within the FDA's authority, please revise
these references to SHL technology's proven efficacy. You may provide relevant
quantitative data from the studies to support your claims.
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.
FirstName LastNameErez Nachtomy
Comapany NameSHL Telemedicine Ltd.
March 20, 2023 Page 2
FirstName LastName
Erez Nachtomy
SHL Telemedicine Ltd.
March 20, 2023
Page 2
You may contact Benjamin Richie at 202-551-7857 or Lauren Nguyen at 202-551-3642
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc: Scott R. Saks