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SEC Comment Letter 0000000000-24-009566 to BIOHARVEST SCIENCES INC. (BHST)

BIOHARVEST SCIENCES INC.
Date: Aug. 21, 2024 · CIK: 0001723464 · Accession: 0000000000-24-009566

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File numbers found in text: 000-56663

Date
August 21, 2024
Author
Tracie Mariner
Form
UPLOAD
Company
BIOHARVEST SCIENCES INC.

Letter

August 21, 2024 Ilan Sobel Chief Executive Officer BioHarvest Sciences Inc. 1140-625 Howe Street Vancouver, BC V6C 2T6, Canada Re:BioHarvest Sciences Inc. Amendment No. 2 to Registration Statement on Form 20-F Filed August 14, 2024 File No. 000-56663 Dear Ilan Sobel: 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 our 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. Amendment No. 2 to Registration Statement on Form 20-F Item 10. Additional Information C. Material Contracts, page 63 1.We note your response to prior comment 1 and reissue in part. Please revise this section to disclose the identities of the other parties to the agreements. 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. Please contact Tracie Mariner at 202-551-3744 or Angela Connell at 202-551-3426 if you have questions regarding comments on the financial statements and related matters. Please contact Daniel Crawford at 202-551-7767 or Alan Campbell at 202-551-4224 with any other questions.

August 21, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Life Sciences cc:Steve O’Neill, Esq.

Show Raw Text
August 21, 2024
Ilan Sobel
Chief Executive Officer
BioHarvest Sciences Inc.
1140-625 Howe Street
Vancouver, BC V6C 2T6, Canada
Re:BioHarvest Sciences Inc.
Amendment No. 2 to Registration Statement on Form 20-F
Filed August 14, 2024
File No. 000-56663
Dear Ilan Sobel:
            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
our 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.
Amendment No. 2 to Registration Statement on Form 20-F
Item 10. Additional Information
C. Material Contracts, page 63
1.We note your response to prior comment 1 and reissue in part. Please revise this section to
disclose the identities of the other parties to the agreements.
            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.
            Please contact Tracie Mariner at 202-551-3744 or Angela Connell at 202-551-3426 if you
have questions regarding comments on the financial statements and related matters. Please
contact Daniel Crawford at 202-551-7767 or Alan Campbell at 202-551-4224 with any other
questions.

August 21, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Steve O’Neill, Esq.