SEC Comment Letter 0000000000-23-002780 to BIMI Holdings Inc. (BIMI) (CIK 0001213660)
BIMI Holdings Inc. (BIMI) (CIK 0001213660)
Date: March 20, 2023 · CIK: 0001213660 · Accession: 0000000000-23-002780
AI Filing Summary & Sentiment
File numbers found in text: 001-34890
Letter
United States securities and exchange commission logo March 20, 2023 Tiewei Song Chief Executive Officer BIMI International Medical Inc. 9th Floor, Building 2 Chongqing Corporation Avenue Yuzhong District, Chongqing, P. R. China, 400010 Re:BIMI International Medical Inc. Amendment No. 1 to Form 10-K for Fiscal Year Ended December 31, 2021 Response dated February 23, 2023 File No. 001-34890 Dear Tiewei Song: We have reviewed your February 23, 2023 response to our comment letter 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 to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our January 24, 2023 letter. Response dated February 23, 2023 General 1.We note your response to prior comment 8, including Appendix A. In your proposed disclosure, you state that you rely on the opinion of your PRC counsel, Chongqing Jiumujinyang (Jiulongpo) Law Firm, regarding whether you or your subsidiaries are subject to the permission requirements of the CAC. Clarify whether counsel is also opining as to the approval requirements of the CSRC, as your disclosure on page 10 of your amended Annual Report file August 31, 2022 seems to suggest. In future filings, please file the consent of your PRC legal counsel as an exhibit.
FirstName LastNameTiewei Song Comapany NameBIMI International Medical Inc. March 20, 2023 Page 2 FirstName LastName Tiewei Song BIMI International Medical Inc. March 20, 2023 Page 2 You may contact Nasreen Mohammed at 202-551-3773 or Adam Phippen at 202-551- 3336 if you have questions regarding comments on the financial statements and related matters. Please contact Kate Beukenkamp at 202-551-3861 or Mara Ransom at 202-551-3264 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Pang Zhang-Whitaker
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United States securities and exchange commission logo
March 20, 2023
Tiewei Song
Chief Executive Officer
BIMI International Medical Inc.
9th Floor, Building 2
Chongqing Corporation Avenue
Yuzhong District, Chongqing,
P. R. China, 400010
Re:BIMI International Medical Inc.
Amendment No. 1 to Form 10-K for Fiscal Year Ended December 31, 2021
Response dated February 23, 2023
File No. 001-34890
Dear Tiewei Song:
We have reviewed your February 23, 2023 response to our comment letter 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 to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
January 24, 2023 letter.
Response dated February 23, 2023
General
1.We note your response to prior comment 8, including Appendix A. In your proposed
disclosure, you state that you rely on the opinion of your PRC counsel, Chongqing
Jiumujinyang (Jiulongpo) Law Firm, regarding whether you or your subsidiaries are
subject to the permission requirements of the CAC. Clarify whether counsel is also
opining as to the approval requirements of the CSRC, as your disclosure on page 10 of
your amended Annual Report file August 31, 2022 seems to suggest. In future filings,
please file the consent of your PRC legal counsel as an exhibit.
FirstName LastNameTiewei Song
Comapany NameBIMI International Medical Inc.
March 20, 2023 Page 2
FirstName LastName
Tiewei Song
BIMI International Medical Inc.
March 20, 2023
Page 2
You may contact Nasreen Mohammed at 202-551-3773 or Adam Phippen at 202-551-
3336 if you have questions regarding comments on the financial statements and related
matters. Please contact Kate Beukenkamp at 202-551-3861 or Mara Ransom at 202-551-3264
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Pang Zhang-Whitaker