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UPLOAD Filing

Scienture Holdings, Inc.
Date: July 24, 2025 · CIK: 0001382574 · Accession: 0000000000-25-007818

Regulatory Compliance Financial Reporting Business Model Clarity

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Date
July 24, 2025
Author
Finance
Form
UPLOAD
Company
Scienture Holdings, Inc.

Letter

Re: Scienture Holdings, Inc. Form 10-K for Fiscal Year Ended December 31, 2024 File No. 1-39199 Dear Narasimhan Mani:

July 24, 2025

Narasimhan Mani Co-Chief Executive Officer and President Scienture Holdings, Inc. 20 Austin Blvd. Commack, NY 11725

We have reviewed your filing and have the following comment.

Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form 10-K for Fiscal Year Ended December 31, 2024 Part I Item 1. Business Current Business - Scienture LLC Research and Development and Product Portfolio, page 6

1. In future filings, please revise your pipeline table so the progress arrow associated with SCN-104 does not enter the "Phase 1" column as it appears you have not filed an IND and commenced the Phase 1 trial for the product candidate. For SCN-106, to the extent you believe you can make an NDA/BLA submission without progressing through all three phases of clinical trials, as depicted in the table, please add appropriate disclosure that makes that clear. Revise to disclose the design and results of the Phase 3 clinical trial for SCN-106, or otherwise revise your pipeline table to indicate the product candidate s current stage of development as it currently appears to state you have completed Phase 3 clinical development. 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. July 24, 2025 Page 2

Please contact Tracie Mariner at 202-551-3744 or Kevin Vaughn at 202-551-3494 if you have questions regarding comments on the financial statements and related matters. Please contact Daniel Crawford at 202-551-7767 or Tim Buchmiller at 202-551- 3635 with any other questions.

Sincerely,
Division of Corporation
Finance
Office of Life Sciences

Show Raw Text
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<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 24, 2025

Narasimhan Mani
Co-Chief Executive Officer and President
Scienture Holdings, Inc.
20 Austin Blvd.
Commack, NY 11725

 Re: Scienture Holdings, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2024
 File No. 1-39199
Dear Narasimhan Mani:

 We have reviewed your filing and have the following comment.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2024
Part I
Item 1. Business
Current Business - Scienture LLC
Research and Development and Product Portfolio, page 6

1. In future filings, please revise your pipeline table so the progress
arrow associated
 with SCN-104 does not enter the "Phase 1" column as it appears you have
not filed an
 IND and commenced the Phase 1 trial for the product candidate. For
SCN-106, to the
 extent you believe you can make an NDA/BLA submission without
progressing
 through all three phases of clinical trials, as depicted in the table,
please add
 appropriate disclosure that makes that clear. Revise to disclose the
design and results
 of the Phase 3 clinical trial for SCN-106, or otherwise revise your
pipeline table to
 indicate the product candidate s current stage of development as it
currently appears
 to state you have completed Phase 3 clinical development.
 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.
 July 24, 2025
Page 2

 Please contact Tracie Mariner at 202-551-3744 or Kevin Vaughn at
202-551-3494 if
you have questions regarding comments on the financial statements and related
matters. Please contact Daniel Crawford at 202-551-7767 or Tim Buchmiller at
202-551-
3635 with any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Life Sciences
</TEXT>
</DOCUMENT>