SEC Comment Letter 0000000000-23-009913 to IceCure Medical Ltd. (ICCM)
IceCure Medical Ltd.
Date: Sept. 7, 2023 · CIK: 0001584371 · Accession: 0000000000-23-009913
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-40753
Letter
United States securities and exchange commission logo September 7, 2023 Ronen Tsimerman Chief Financial Officer IceCure Medical Ltd. 7 Ha’Eshel St., PO Box 3163 Caesarea, 3079504 Israel Re:IceCure Medical Ltd. Form 20-F filed March 29, 2023 File No. 001-40753 Dear Ronen Tsimerman: 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 to these comments, we may have additional comments. Annual Report on Form 20-F filed March 29, 2023 General 1.We note your disclosure that two of your three subsidiaries are in China, your 52.7% shareholder and multiple members of your Board of Directors are based in China, and geographically, it appears that a significant portion of your revenue is generated in China. Please review the Division of Corporation Finance's December 20, 2021, guidance "Sample Letter to China-Based Companies" available at https://www.sec.gov/corpfin/sample-letter-china-based-companies and provide us with an analysis of whether you are based in or have the majority of your operations in China, which includes Hong Kong. If so, please update your disclosure to fully discuss the legal and operational risks associated with being a China-based company, or explain why such comments are not applicable to the company. 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 LastNameRonen Tsimerman Comapany NameIceCure Medical Ltd. September 7, 2023 Page 2 FirstName LastName Ronen Tsimerman IceCure Medical Ltd. September 7, 2023 Page 2 You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if you have questions regarding comments on the financial statements and related matters. Please contact Benjamin Richie at 202-551-7857 or Abby Adams at 202-551-6902 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
September 7, 2023
Ronen Tsimerman
Chief Financial Officer
IceCure Medical Ltd.
7 Ha’Eshel St., PO Box 3163
Caesarea, 3079504 Israel
Re:IceCure Medical Ltd.
Form 20-F filed March 29, 2023
File No. 001-40753
Dear Ronen Tsimerman:
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 to these comments, we may have additional comments.
Annual Report on Form 20-F filed March 29, 2023
General
1.We note your disclosure that two of your three subsidiaries are in China, your 52.7%
shareholder and multiple members of your Board of Directors are based in China, and
geographically, it appears that a significant portion of your revenue is generated in
China. Please review the Division of Corporation Finance's December 20, 2021, guidance
"Sample Letter to China-Based Companies" available at
https://www.sec.gov/corpfin/sample-letter-china-based-companies and provide us with an
analysis of whether you are based in or have the majority of your operations in China,
which includes Hong Kong. If so, please update your disclosure to fully discuss the legal
and operational risks associated with being a China-based company, or explain why such
comments are not applicable to the company.
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 LastNameRonen Tsimerman
Comapany NameIceCure Medical Ltd.
September 7, 2023 Page 2
FirstName LastName
Ronen Tsimerman
IceCure Medical Ltd.
September 7, 2023
Page 2
You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters. Please
contact Benjamin Richie at 202-551-7857 or Abby Adams at 202-551-6902 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services