SEC Comment Letter for InMode Ltd. (INMD) (CIK 0001742692) (INMD) — Mar 28, 2019
InMode Ltd. (INMD) (CIK 0001742692)
Date: March 28, 2019 · CIK: 0001742692 · Accession: 0000000000-19-006039
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March 27, 2019
Moshe Mizrahy
Chief Executive Officer
InMode Ltd.
Tavor Building, Sha’ar Yokneam
P.O. Box 533
Yokneam 2069200, Israel
Re:InMode Ltd.
Amendment No. 4 to
Draft Registration Statement on Form F-1
Submitted March 13, 2019
CIK No. 0001742692
Dear Mr. Mizrahy:
We have reviewed your amended draft registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 revised March 13, 2019
Revenues, page 52
1.Other than the products named in the second paragraph of this section, please tell us
which products contributed to your revenue during the period mentioned in Form 20-F
Item 4.B.1 and the percentage of your revenue contributed by those products.
Certain Relationships and Related Party Transactions, page 113
2.We note your deletions in this section. Please ensure that you have provided disclosure
for all periods required to be addressed by Form 20-F Item 7.B.
FirstName LastNameMoshe Mizrahy
Comapany NameInMode Ltd.
March 27, 2019 Page 2
FirstName LastName
Moshe Mizrahy
InMode Ltd.
March 27, 2019
Page 2
Exhibit Index, page II-5
3.Please file the 2019 sublicense mentioned in your revision on page 27 and the 2019
waiver mentioned at the bottom of page 113.
You may contact Jeanne Bennett at 202-551-3606 or Brian Cascio, Accounting Branch
Chief, at 202-551-3676 if you have questions regarding comments on the financial statements
and related matters. Please contact Heather Percival at 202-551-3498 or Russell Mancuso, Legal
Branch Chief, at 202-551-3617 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery
cc: Brian D. Hirshberg