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UPLOAD Filing

BeOne Medicines Ltd.
Date: June 2, 2025 · CIK: 0001651308 · Accession: 0000000000-25-005783

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File numbers found in text: 001-3786

Date
June 2, 2025
Author
Finance
Form
UPLOAD
Company
BeOne Medicines Ltd.

Letter

Re: BeOne Medicines Ltd. Form 10-K for the Fiscal Year Ended December 31, 2024 File No. 001-3786 Dear Aaron Rosenberg:

June 2, 2025

Aaron Rosenberg Chief Financial Officer BeOne Medicines Ltd. c/o Mourant Governance Services (Cayman) Limited 94 Solaris Avenue, Camana Bay

We have reviewed your filing and have the following comment.

Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form 10-K for Fiscal Year Ended December 31, 2024 Notes to the Consolidated Financial Statements 3. Collaborative and Licensing Arrangements, page 151

1. You disclose that other collaboration revenue consists primarily of revenue under the Novartis broad markets agreement and, beginning in 2024, royalty revenue under the Amgen collaboration agreement. Please revise your future filings to clarify the products to which the Amgen royalty revenue relates. In this regard, your disclosure on page 153 indicates that beginning in October 2019 you were responsible for the commercialization of XGEVA, KYPROLIS and BLINCYTO in China for a period of five to seven years, and that following the commercialization period you have the right to retain one product and receive royalties on sales in China for an additional five years on the products not retained. Clarify whether the commercialization period has ended for any of these products and if not, to which products the royalty revenue relates. 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. June 2, 2025 Page 2

Please contact Bonnie Baynes at 202-551-4924 or Angela Connell at 202-551- 3426 with any questions.

Sincerely,
Division of Corporation
Finance
Office of Life Sciences

Show Raw Text
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<TEXT>
 June 2, 2025

Aaron Rosenberg
Chief Financial Officer
BeOne Medicines Ltd.
c/o Mourant Governance Services (Cayman) Limited
94 Solaris Avenue, Camana Bay

 Re: BeOne Medicines Ltd.
 Form 10-K for the Fiscal Year Ended December 31, 2024
 File No. 001-3786
Dear Aaron Rosenberg:

 We have reviewed your filing and have the following comment.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2024
Notes to the Consolidated Financial Statements
3. Collaborative and Licensing Arrangements, page 151

1. You disclose that other collaboration revenue consists primarily of
revenue under the
 Novartis broad markets agreement and, beginning in 2024, royalty revenue
under the
 Amgen collaboration agreement. Please revise your future filings to
clarify the
 products to which the Amgen royalty revenue relates. In this regard,
your disclosure
 on page 153 indicates that beginning in October 2019 you were
responsible for the
 commercialization of XGEVA, KYPROLIS and BLINCYTO in China for a period
of
 five to seven years, and that following the commercialization period you
have the
 right to retain one product and receive royalties on sales in China for
an additional
 five years on the products not retained. Clarify whether the
commercialization period
 has ended for any of these products and if not, to which products the
royalty revenue
 relates.
 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.
 June 2, 2025
Page 2

 Please contact Bonnie Baynes at 202-551-4924 or Angela Connell at
202-551-
3426 with any questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Life Sciences
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