SecProbe.io

February 12, 2020
Johnny Cheng
Chief Financial Officer
Hutchison China MediTech Ltd
Level 18, Metropolis Tower
10 Metropolis Drive
Hunghom, Kowloon
Hong Kong
Re:Hutchison China MediTech Ltd
Form 20-F for the Fiscal Year Ended December 31, 2018
Form 6-K filed July 30, 2019 for the Month of July 2019
File No. 001-37710
Dear Mr. Cheng:
            We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 20-F for the Fiscal Year Ended December 31, 2018
Note 23. Segment Reporting, page F-51
1.Your response to prior comment 2 indicates that you will revise your disclosure on
segment reporting to clarify that the performance of your reportable segments is assessed
based on operating (loss) profit.  We have the following additional comments:
•We note that operating (loss) profit as presented in your segment footnote differs
from your loss from operations as presented in your consolidated statement of
operations.  Please rename this measure to prevent confusion to shareholders; and
•Please confirm that you will no longer include Adjusted (LBIT)/EBIT in your
segment tabular presentation.  In this regard, we note that this is a non-GAAP
measure and pursuant to Rule 10(e)(1)(ii)(c) of Regulation S-K, it is not appropriate
to include non-GAAP measures in notes to the financial statements.

 FirstName LastNameJohnny Cheng
 Comapany NameHutchison China MediTech Ltd
 February 12, 2020 Page 2
 FirstName LastName
Johnny Cheng
Hutchison China MediTech Ltd
February 12, 2020
Page 2
Form 6-K filed July 30, 2019 for the Month of July 2019
Exhibit 99.1
Use of Non-GAAP Financial Measures and Reconciliations, page 27
2.We note your response to prior comment 3 and have the following additional comments
regarding your newly named non-GAAP measure, adjusted Innovation Platform segment
operating loss:
•Please more fully explain the nature of the revenues that are reported in this segment.
Please also clarify why management believes the exclusion of fees paid by your
collaboration partners for the performance of certain research and development
services provides useful information to investors about your ongoing total investment
associated with the resources allocated to progressing your R&D pipeline.
Specifically, address whether the research and development expenses recognized
related to fees paid by your collaboration partners would have been incurred without
such funding; and
•Tell us more about your relationship with Nutrition Science Partners.  Explain the
nature of the service fees charged by a subsidiary of Chi-Med to Nutrition Science
Partners and how these fees are reflected in your segment operating loss measure.  In
this regard, we note that these service fees represent a significant portion of Nutrition
Science Partners’ Loss.
            In closing, 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.
            You may contact Jenn Do at (202) 551-3743 or Jeanne Baker at (202) 551-3691 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences