SEC Comment Letter 0000000000-23-003071 to SHL TELEMEDICINE LTD (SHLT) (CIK 0001166834) (SHMLF)
SHL TELEMEDICINE LTD (SHLT) (CIK 0001166834)
Date: March 28, 2023 · CIK: 0001166834 · Accession: 0000000000-23-003071
AI Filing Summary & Sentiment
File numbers found in text: 001-41641
Letter
United States securities and exchange commission logo March 28, 2023 Erez Nachtomy Chief Executive Officer SHL Telemedicine Ltd. 90 Yigal Alon Street Tel Aviv 67891, Israel Re:SHL Telemedicine Ltd. Amendment No. 2 to Registration Statement on Form 20FR12B Filed March 24, 2023 File No. 001-41641 Dear Erez Nachtomy: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply 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 these comments, we may have additional comments. Amendment No. 2 to Form 20FR12B Jury Trial Waiver, page 119 1.We note the newly filed Exhibit 2.1 and your new disclosure relating to the Company’s exclusive forum provision in the deposit agreement. Please revise the relevant risk factors section to include disclosure that ADS holders may be subject to increased costs to bring a claim and that these provisions can discourage claims or limit investors’ ability to bring a claim in a judicial forum that they find favorable.
FirstName LastNameErez Nachtomy Comapany NameSHL Telemedicine Ltd. March 28, 2023 Page 2 FirstName LastName Erez Nachtomy SHL Telemedicine Ltd. March 28, 2023 Page 2 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. You may contact Julie Sherman at 202-551-3640 or Al Pavot at 202-551-3738 if you have questions regarding comments on the financial statements and related matters. Please 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 28, 2023
Erez Nachtomy
Chief Executive Officer
SHL Telemedicine Ltd.
90 Yigal Alon Street
Tel Aviv 67891, Israel
Re:SHL Telemedicine Ltd.
Amendment No. 2 to Registration Statement on Form 20FR12B
Filed March 24, 2023
File No. 001-41641
Dear Erez Nachtomy:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments 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
comments apply 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 these
comments, we may have additional comments.
Amendment No. 2 to Form 20FR12B
Jury Trial Waiver, page 119
1.We note the newly filed Exhibit 2.1 and your new disclosure relating to the Company’s
exclusive forum provision in the deposit agreement. Please revise the relevant risk factors
section to include disclosure that ADS holders may be subject to increased costs to bring a
claim and that these provisions can discourage claims or limit investors’ ability to bring a
claim in a judicial forum that they find favorable.
FirstName LastNameErez Nachtomy
Comapany NameSHL Telemedicine Ltd.
March 28, 2023 Page 2
FirstName LastName
Erez Nachtomy
SHL Telemedicine Ltd.
March 28, 2023
Page 2
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.
You may contact Julie Sherman at 202-551-3640 or Al Pavot at 202-551-3738 if you
have questions regarding comments on the financial statements and related matters. Please
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