SEC Comment Letter for HUTCHMED (China) Ltd (HCM, HMDCF) (CIK 0001648257) (HCM) — Dec 2, 2015
HUTCHMED (China) Ltd (HCM, HMDCF) (CIK 0001648257)
Date: Dec. 2, 2015 · CIK: 0001648257 · Accession: 0000000000-15-056069
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-207447
Letter
Mail Stop 4546 December 1, 2015 Via E -mail Christian Hogg Chief Executive Officer Hutchison China MediTech Limited Room 2108, 21/F, Hutchison House 10 Harcourt Road Hong Kong
Re: Hutchison China MediTech Limited Amendment No. 1 to Registration Statement on Form F -1 Filed November 13 , 2015 File No. 333-207447
Dear Mr. Hogg :
We have reviewed your amended registration statement 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 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 a ppropriate, 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.
Cover page
1. We note your statement that your ordinary shares are listed on the AIM market of the London Stock Exchange and that on ____, 2015, the closing sale price of your ordinary shares on the AIM market was ____ per share, equivalent to a price of $ ____ per ADS. Please revise to specifically state that you will price your offering of ADSs at the U.S. dollar equivalent of the closing sale price of your ordinary shares on the AIM market on the previous trading day or otherwise clarify how you will use the closing sale price per the AIM market to set your offering price.
Christian Hogg Hutchison China MediTech Limited December 1, 2015 Page 2
You may contact Christine Torney, Staff Accoun tant, at (202) 551 -3652 or James Rosenberg, Senior Assistant Chief Accountant, at (202) 551 -3679 if you have questions regarding comments on the finan cial statements and related matters. Please contact Alexandra M. Ledbetter, Staff Attorney, at (202) 551 -3317 or me at (202) 551 -3675 with any other questions.
Sincerely,
/s/ Suzanne Hayes
Show Raw Text
Mail Stop 4546
December 1, 2015
Via E -mail
Christian Hogg
Chief Executive Officer
Hutchison China MediTech Limited
Room 2108, 21/F, Hutchison House
10 Harcourt Road
Hong Kong
Re: Hutchison China MediTech Limited
Amendment No. 1 to Registration Statement on Form F -1
Filed November 13 , 2015
File No. 333-207447
Dear Mr. Hogg :
We have reviewed your amended registration statement 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 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 a ppropriate, 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.
Cover page
1. We note your statement that your ordinary shares are listed on the AIM market of the
London Stock Exchange and that on ____, 2015, the closing sale price of your ordinary
shares on the AIM market was ____ per share, equivalent to a price of $ ____ per ADS.
Please revise to specifically state that you will price your offering of ADSs at the U.S.
dollar equivalent of the closing sale price of your ordinary shares on the AIM market on
the previous trading day or otherwise clarify how you will use the closing sale price per
the AIM market to set your offering price.
Christian Hogg
Hutchison China MediTech Limited
December 1, 2015
Page 2
You may contact Christine Torney, Staff Accoun tant, at (202) 551 -3652 or James
Rosenberg, Senior Assistant Chief Accountant, at (202) 551 -3679 if you have questions
regarding comments on the finan cial statements and related matters. Please contact Alexandra
M. Ledbetter, Staff Attorney, at (202) 551 -3317 or me at (202) 551 -3675 with any other
questions.
Sincerely,
/s/ Suzanne Hayes
Suzanne Hayes
Assistant Director
Office of Healthcare and Insurance
cc: Paul Boltz
Ropes & Gray
Mary Kathryn Papaioannou
Ropes & Gray
Jimmy Gao
Ropes & Gray