SEC Comment Letter for MediWound Ltd. (MDWD) (CIK 0001593984) (MDWD) — Apr 8, 2019
MediWound Ltd. (MDWD) (CIK 0001593984)
Date: April 8, 2019 · CIK: 0001593984 · Accession: 0000000000-19-006753
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File numbers found in text: 333-230490
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April 8, 2019
Gal Cohen
Chief Executive Officer
MediWound Ltd.
42 Hayarkon Street
Yavne 8122745, Israel
Re:MediWound Ltd.
Registration Statement on Form F-3
Filed March 25, 2019
File No. 333-230490
Dear Mr. Cohen:
We have limited our review of your registration statement to those issues we have
addressed in our 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 this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form F-3
General
1.Please provide us with support for your conclusion that you are eligible to conduct a
primary offering under General Instruction I.B.1 of Form F-3. In this regard, provide us
with your calculation of the aggregate market value of the shares held by non-affiliates.
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
FirstName LastNameGal Cohen
Comapany NameMediWound Ltd.
April 8, 2019 Page 2
FirstName LastName
Gal Cohen
MediWound Ltd.
April 8, 2019
Page 2
Please contact Tonya K. Aldave at (202) 551-3601 or Justin Dobbie, Legal Branch Chief,
at (202) 551-3469 with any questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Nathan Ajiashvili, Esq.