SEC Comment Letter 0000000000-23-012624 to Zai Lab Ltd (ZLAB)
Zai Lab Ltd
Date: Nov. 17, 2023 · CIK: 0001704292 · Accession: 0000000000-23-012624
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File numbers found in text: 001-38205
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United States securities and exchange commission logo
November 17, 2023
Yajing Chen
Chief Financial Officer
Zai Lab Ltd
4560 Jinke Road
Bldg. 1, Fourth Floor
Pudong, Shanghai, China 201210
Re:Zai Lab Ltd
Form 10-K for Fiscal Year Ended December 31, 2022
Response dated September 20, 2023
File No. 001-38205
Dear Yajing Chen:
We have reviewed your September 20, 2023 response to our comment letter 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. Unless
we note otherwise, any references to prior comments are to comments in our September 13,
2023 letter.
Form 10-K for Fiscal Year Ended December 31, 2022
General
1.We note your response to prior comment 1 and continue to believe that you
should provide the documentation required by Item 9C of Form 10-K. Additionally,
please amend your Form 10-K to provide the disclosures required under Item 9C(b) of
Form 10-K. Refer to the Staff Statement on the Holding Foreign Companies Accountable
Act and the Consolidated Appropriations Act, 2023, available on our website at
https://www.sec.gov/corpfin/announcement/statement-hfcaa-040623.
FirstName LastNameYajing Chen
Comapany NameZai Lab Ltd
November 17, 2023 Page 2
FirstName LastName
Yajing Chen
Zai Lab Ltd
November 17, 2023
Page 2
Please contact Jennifer Gowetski at 202-551-3401 or Andrew Mew at 202-551-3377 with
any other questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Aslynn Hogue