SEC Comment Letter for InMode Ltd. (INMD) (CIK 0001742692) (INMD) — Aug 1, 2019
InMode Ltd. (INMD) (CIK 0001742692)
Date: Aug. 1, 2019 · CIK: 0001742692 · Accession: 0000000000-19-011934
AI Filing Summary & Sentiment
File numbers found in text: 333-232615
Letter
August 1, 2019 Moshe Mizrahy Chief Executive Officer InMode Ltd. Tavor Building, Sha’ar Yokneam P.O. Box 533 Yokneam 2069206, Israel Re:InMode Ltd. Amendment No. 1 to Registration Statement on Form F-1 Filed July 29, 2019 File No. 333-232615 Dear Mr. Mizrahy: We have reviewed your amended 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 amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Form F-1 Amended July 29, 2019 General 1.Please clarify whether your references to counsel in your prospectus are to the counsel whose consent is included in exhibit 5.1. We note for example your disclosure on page 155. Exhibit Index, page II-5 2.Please include the exhibit required by Regulation S-K Item 601(b)(24).
FirstName LastNameMoshe Mizrahy Comapany NameInMode Ltd. August 1, 2019 Page 2 FirstName LastName Moshe Mizrahy InMode Ltd. August 1, 2019 Page 2 Exhibits 3.We note that the opinion filed as exhibit 5.1 appears to be conditioned on effectiveness of your amended articles of association. The opinion that you file per Regulation S-K Item 601(b)(5) should not assume that the registrant has taken corporate actions necessary to authorize the issuance of the securities. For guidance, see also the fourth bullet point in section II.B.3.a of Staff Legal Bulletin No. 19 (October 14, 2011). Please file a revised opinion as appropriate. 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
Show Raw Text
August 1, 2019
Moshe Mizrahy
Chief Executive Officer
InMode Ltd.
Tavor Building, Sha’ar Yokneam
P.O. Box 533
Yokneam 2069206, Israel
Re:InMode Ltd.
Amendment No. 1 to Registration Statement on Form F-1
Filed July 29, 2019
File No. 333-232615
Dear Mr. Mizrahy:
We have reviewed your amended 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 amending your registration statement and providing the
requested information. 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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form F-1 Amended July 29, 2019
General
1.Please clarify whether your references to counsel in your prospectus are to the counsel
whose consent is included in exhibit 5.1. We note for example your disclosure on page
155.
Exhibit Index, page II-5
2.Please include the exhibit required by Regulation S-K Item 601(b)(24).
FirstName LastNameMoshe Mizrahy
Comapany NameInMode Ltd.
August 1, 2019 Page 2
FirstName LastName
Moshe Mizrahy
InMode Ltd.
August 1, 2019
Page 2
Exhibits
3.We note that the opinion filed as exhibit 5.1 appears to be conditioned on effectiveness of
your amended articles of association. The opinion that you file per Regulation S-K Item
601(b)(5) should not assume that the registrant has taken corporate actions necessary to
authorize the issuance of the securities. For guidance, see also the fourth bullet point in
section II.B.3.a of Staff Legal Bulletin No. 19 (October 14, 2011). Please file a revised
opinion as appropriate.
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