Correspondence 0001213900-23-032033 from BIMI Holdings Inc. (BIMI) (CIK 0001213660)
BIMI Holdings Inc. (BIMI) (CIK 0001213660)
Date: April 24, 2023 · CIK: 0001213660 · Accession: 0001213900-23-032033
AI Filing Summary & Sentiment
File numbers found in text: 001-34890
Referenced dates: March 20, 2023
Letter
Amendment No. 1 to Form 10-K for the Fiscal Year Ended December 31, 2021 Response dated February 23, 2023 File No.: 001-34890
Re: BIMI International Medical Inc.
Dear Ladies and Gentlemen:
We are submitting this letter in response to your letter dated March 20, 2023 in which the staff of the Division of Corporation Finance (the “Staff”) provided further comments to our response dated February 23, 2023 to the Staff’s comments with respect to the Amendment No. 1 to the Form 10-K we filed on August 31, 2022.
Set forth below are our responses to the comments. For your convenience, the text of each of such comments are reproduced in italics before our response.
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.
Yes, counsel is also opining as to the approval requirements of the CSRC, as the disclosure on page 10 of our amended Annual Report filed on August 31, 2022 indicated.
In future filings, we will file the consent of our PRC legal counsel as an exhibit.
If you have any further questions, please do not hesitate to contact our counsel, Ms. Pang Zhang -Whitaker of Carter Ledyard & Milburn LLP at 212-238-8844.
Very truly yours,
BIMI International Medical Inc.
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BIMI
International medical inc. (NASDAQ: BIMI)
April 24, 2023
U.S. Securities and Exchange
Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn: Ms. Nasreen Mohammed
Re:
BIMI International Medical Inc.
Amendment No. 1 to Form 10-K for the Fiscal Year Ended December 31, 2021
Response dated February 23, 2023
File No.: 001-34890
Dear Ladies and Gentlemen:
We are submitting this letter in response to your letter
dated March 20, 2023 in which the staff of the Division of Corporation Finance (the “Staff”) provided further comments to
our response dated February 23, 2023 to the Staff’s comments with respect to the Amendment No. 1 to the Form 10-K we filed on August
31, 2022.
Set forth below are our responses to the comments.
For your convenience, the text of each of such comments are reproduced in italics before our response.
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.
Yes, counsel is also opining as to the approval requirements
of the CSRC, as the disclosure on page 10 of our amended Annual Report filed on August 31, 2022 indicated.
In future filings, we will file the consent of our PRC legal
counsel as an exhibit.
If you have any further questions, please do not
hesitate to contact our counsel, Ms. Pang Zhang -Whitaker of Carter Ledyard & Milburn LLP at 212-238-8844.
Very truly yours,
BIMI International Medical Inc.
By:
/s/ Tiewi Song
Chief Executive Officer