SEC Comment Letter for Biodexa Pharmaceuticals Plc (BDRX) (CIK 0001643918) (BDRX) — Oct 3, 2019
Biodexa Pharmaceuticals Plc (BDRX) (CIK 0001643918)
Date: Oct. 3, 2019 · CIK: 0001643918 · Accession: 0000000000-19-014247
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File numbers found in text: 333-233901
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October 3, 2019
Craig Cook
Chief Executive Officer
Midatech Pharma PLC
Oddfellows House
19 Newport Road
Cardiff, United Kingdom
CF24 OAA
Re:Midatech Pharma PLC
Registration Statement on Form F-3
Filed September 23, 2019
File No. 333-233901
Dear Dr. Cook:
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 refer to Section 7.6 of Exhibit 4.2. We note that the depositary is entitled to refer
any dispute or difference for final settlement by arbitration in accordance with the
Commercial Arbitration Rules of the American Arbitration Association. Please revise the
prospectus to describe the arbitration provision and to disclose the impact of this provision
on holders of your ADSs for claims under the federal securities laws.
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 LastNameCraig Cook
Comapany NameMidatech Pharma PLC
October 3, 2019 Page 2
FirstName LastName
Craig Cook
Midatech Pharma PLC
October 3, 2019
Page 2
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.
Please contact Donald Field at 202-551-3680 or Justin Dobbie at 202-551-3469 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences