SEC Comment Letter for Aptorum Group Ltd (APM) (CIK 0001734005) (NIKI) — Oct 11, 2018
Aptorum Group Ltd (APM) (CIK 0001734005)
Date: Oct. 11, 2018 · CIK: 0001734005 · Accession: 0000000000-18-031953
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-227198
Letter
October 11, 2018 Ian Huen Chief Executive Officer Aptorum Group Ltd 17th Floor, Guangdong Investment Tower 148 Connaught Road Central Hong Kong Re:Aptorum Group Ltd. Amendment No.1 to Registration Statement on Form F-1 Filed October 5, 2018 File No. 333-227198 Dear Mr. Huen: We have reviewed your amended registration statement 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 letter by amending your registration statement and providing the requested information. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to the comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 20, 2018 letter. Amendment No. 1 to Form F-1 filed on October 5, 2018 Our Business Statistical Significance, page 82 1.We note your response to comment 4 and your disclosure that you do not intend to use for any regulatory submission the standard of statistical testing that you have employed to compare different treatment groups. Please revise your disclosure to explain how standards for statistical significance relate to the U.S. Food and Drug Adminstration’s evidentiary standards of efficacy.
FirstName LastNameIan Huen Comapany NameAptorum Group Ltd October 11, 2018 Page 2 FirstName LastName Ian Huen Aptorum Group Ltd October 11, 2018 Page 2 You may contact Keira Nakada at 202-551-3659 or Angela Connell at 202-551-3426 if you have questions regarding comments on the financial statements and related matters. Please contact Christine Westbrook at 202-551-5019 or Mary Beth Breslin at 202-551-3625 with any other questions. Sincerely, Division of Corporation Finance Office of Healthcare & Insurance cc: Louis Taubman, Esq.
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October 11, 2018
Ian Huen
Chief Executive Officer
Aptorum Group Ltd
17th Floor, Guangdong Investment Tower
148 Connaught Road Central
Hong Kong
Re:Aptorum Group Ltd.
Amendment No.1 to Registration Statement on Form F-1
Filed October 5, 2018
File No. 333-227198
Dear Mr. Huen:
We have reviewed your amended registration statement 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 letter by amending your registration statement and providing the
requested information. If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to the comment, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our September 20, 2018 letter.
Amendment No. 1 to Form F-1 filed on October 5, 2018
Our Business
Statistical Significance, page 82
1.We note your response to comment 4 and your disclosure that you do not intend to use for
any regulatory submission the standard of statistical testing that you have employed to
compare different treatment groups. Please revise your disclosure to explain how
standards for statistical significance relate to the U.S. Food and Drug Adminstration’s
evidentiary standards of efficacy.
FirstName LastNameIan Huen
Comapany NameAptorum Group Ltd
October 11, 2018 Page 2
FirstName LastName
Ian Huen
Aptorum Group Ltd
October 11, 2018
Page 2
You may contact Keira Nakada at 202-551-3659 or Angela Connell at 202-551-3426 if
you have questions regarding comments on the financial statements and related matters. Please
contact Christine Westbrook at 202-551-5019 or Mary Beth Breslin at 202-551-3625 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Louis Taubman, Esq.