SEC Company Response from Aptorum Group Ltd (APM) (CIK 0001734005) (NIKI) — Oct 16, 2019
Aptorum Group Ltd (APM) (CIK 0001734005)
Date: Oct. 16, 2019 · CIK: 0001734005 · Accession: 0001213900-19-020423
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File numbers found in text: 333-232510
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CORRESP
1
filename1.htm
APTORUM
GROUP LIMITED
17th
Floor, Guangdong Investment Tower
148
Connaught Road Central
Hong
Kong
October
16, 2019
VIA
EDGAR
U.S.
Securities and Exchange Commission
Division
of Corporation Finance
Office
of Healthcare & Insurance
100
F Street, N.E.
Mail
Stop 4631
Washington,
DC 20549
Re:
Aptorum Group Ltd.
Amendment
No. 2 to Registration Statement on Form F-1
Filed
September 27, 2019
File
No. 333-232510
Dear
Sir and Madam:
Aptorum
Group Limited (the “Company,” “Aptorum,” “we,” “us” or “our”)
hereby transmits its response to the verbal comments our counsel, Louis Taubman, received from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”), on October 11, 2019, regarding our Registration
Statement on Form F-1 previously submitted on July 2, 2019 and amended on August 16, 2019 and September 27, 2019 (the “Registration
Statement”). For ease of reference, we have written our understanding of the Commission’s comments in this response
and provided our response thereto. An amended F-1 submitted publicly accompanying this Response Letter is referred to as Form
F-1.
1. Please
revise the registration statement to remove reference to the website relating to where
interested parties may find information related to the referenced Token offering. The
information in this website contains more information than is permitted under Rule 902.
Response:
We have removed all such references from the amendment being filed on this same date.
We
thank the Staff for your review of the foregoing. If you have further comments, we ask that you forward them by electronic mail
to our counsel, Louis Taubman at ltaubman@htflawyers.com or by telephone at (917) 512-0827.
/s/
Ian Huen
Ian
Huen
CEO
cc:
Louis
Taubman
Hunter
Taubman Fischer& Li LLC