SEC Comment Letter 0000000000-23-010452 to BeOne Medicines Ltd. (BEIGF)
BeOne Medicines Ltd.
Date: Sept. 21, 2023 · CIK: 0001651308 · Accession: 0000000000-23-010452
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-37686
Letter
United States securities and exchange commission logo September 21, 2023 John V. Oyler Chief Executive Officer BeiGene, Ltd. 94 Solaris Avenue, Camana Bay Grand Cayman Cayman Islands KY1-1108 Re:BeiGene, Ltd. Form 10-K for the Fiscal Year Ended December 31, 2022 File No. 001-37686 Dear John V. Oyler: We have reviewed your August 21, 2023 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 this comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Our reference to a prior comment is to a comment in our July 21, 2023 letter.
FirstName LastNameJohn V. Oyler Comapany NameBeiGene, Ltd. September 21, 2023 Page 2 FirstName LastName John V. Oyler BeiGene, Ltd. September 21, 2023 Page 2 Form 10-K for the Fiscal Year Ended December 31, 2022 Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 135 1.As noted in your response to prior comment 3, Item 16I(b) of Form 20-F states: “Also, any such identified foreign issuer that uses a variable-interest entity or any similar structure [emphasis added] that results in additional foreign entities being consolidated in the financial statements of the registrant is required to provide the below disclosures for itself and its consolidated foreign operating entity or entities.” Additionally, page 15 of our Release No. 34-93701, “Holding Foreign Companies Accountable Act Disclosure,” clarifies that a registrant should “look through a VIE or any structure [emphasis added] that results in additional foreign entities being consolidated in the financial statements of the registrant and provide the required disclosures about any consolidated operating company or companies in the relevant jurisdiction.” As previously requested, please provide us with the information required by Items 16I(b)(2) through (b)(5) for all of your consolidated foreign operating entities in your supplemental response. Please contact Kyle Wiley at (202) 344-5791 or Jennifer Gowetski at (202) 551-3401 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Edwin M. O'Connor
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United States securities and exchange commission logo
September 21, 2023
John V. Oyler
Chief Executive Officer
BeiGene, Ltd.
94 Solaris Avenue, Camana Bay
Grand Cayman
Cayman Islands KY1-1108
Re:BeiGene, Ltd.
Form 10-K for the Fiscal Year Ended December 31, 2022
File No. 001-37686
Dear John V. Oyler:
We have reviewed your August 21, 2023 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment 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 this
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments. Our
reference to a prior comment is to a comment in our July 21, 2023 letter.
FirstName LastNameJohn V. Oyler
Comapany NameBeiGene, Ltd.
September 21, 2023 Page 2
FirstName LastName
John V. Oyler
BeiGene, Ltd.
September 21, 2023
Page 2
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 135
1.As noted in your response to prior comment 3, Item 16I(b) of Form 20-F states: “Also,
any such identified foreign issuer that uses a variable-interest entity or any similar
structure [emphasis added] that results in additional foreign entities being consolidated in
the financial statements of the registrant is required to provide the below disclosures for
itself and its consolidated foreign operating entity or entities.” Additionally, page 15 of
our Release No. 34-93701, “Holding Foreign Companies Accountable Act Disclosure,”
clarifies that a registrant should “look through a VIE or any structure [emphasis added]
that results in additional foreign entities being consolidated in the financial statements of
the registrant and provide the required disclosures about any consolidated operating
company or companies in the relevant jurisdiction.” As previously requested, please
provide us with the information required by Items 16I(b)(2) through (b)(5) for all of your
consolidated foreign operating entities in your supplemental response.
Please contact Kyle Wiley at (202) 344-5791 or Jennifer Gowetski at (202) 551-3401
with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Edwin M. O'Connor