SEC Comment Letter for Aesthetic Medical International Holdings Group Ltd (PAIYY) (CIK 0001757143) (PAIYY) — Jul 8, 2019
Aesthetic Medical International Holdings Group Ltd (PAIYY) (CIK 0001757143)
Date: July 8, 2019 · CIK: 0001757143 · Accession: 0000000000-19-010848
AI Filing Summary & Sentiment
Letter
July 8, 2019 Zhou Pengwu Chief Executive Officer Aesthetic Medical International Holdings Group Ltd. 1122 Nanshan Boulevard Nanshan District, Shenzhen Guangdong Province, China 518052 Re:Aesthetic Medical International Holdings Group Ltd. Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted May 30, 2019 CIK No. 0001757143 Dear Dr. Pengwu: We have reviewed your amended draft 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 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 this comment and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 2 to Draft Registration Statement on Form F-1 Recent developments, page 7 1.We note your disclosure of estimated preliminary results for the three months ended March 31, 2019, and specifically, your reference to revenue growth. Please revise these recent development disclosures to include a balanced discussion of both revenues and a measure of income, such as net income/loss. You may contact Charles Eastman, Staff Accountant, at (202) 551-3794 or Robert S. Littlepage, Accountant Branch Chief, at (202) 551-3361 if you have questions regarding
FirstName LastNameZhou Pengwu Comapany NameAesthetic Medical International Holdings Group Ltd. July 8, 2019 Page 2 FirstName LastName Zhou Pengwu Aesthetic Medical International Holdings Group Ltd. July 8, 2019 Page 2 comments on the financial statements and related matters. Please contact Joshua Shainess, Attorney-Adviser, at (202) 551-7951 or Celeste M. Murphy, Legal Branch Chief, at (202) 551- 3257 with any other questions. Sincerely, Division of Corporation Finance Office of Telecommunications
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July 8, 2019
Zhou Pengwu
Chief Executive Officer
Aesthetic Medical International Holdings Group Ltd.
1122 Nanshan Boulevard
Nanshan District, Shenzhen
Guangdong Province, China 518052
Re:Aesthetic Medical International Holdings Group Ltd.
Amendment No. 1 to
Draft Registration Statement on Form F-1
Submitted May 30, 2019
CIK No. 0001757143
Dear Dr. Pengwu:
We have reviewed your amended draft 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 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 this comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 2 to Draft Registration Statement on Form F-1
Recent developments, page 7
1.We note your disclosure of estimated preliminary results for the three months ended
March 31, 2019, and specifically, your reference to revenue growth. Please revise
these recent development disclosures to include a balanced discussion of both revenues
and a measure of income, such as net income/loss.
You may contact Charles Eastman, Staff Accountant, at (202) 551-3794 or Robert S.
Littlepage, Accountant Branch Chief, at (202) 551-3361 if you have questions regarding
FirstName LastNameZhou Pengwu
Comapany NameAesthetic Medical International Holdings Group Ltd.
July 8, 2019 Page 2
FirstName LastName
Zhou Pengwu
Aesthetic Medical International Holdings Group Ltd.
July 8, 2019
Page 2
comments on the financial statements and related matters. Please contact Joshua Shainess,
Attorney-Adviser, at (202) 551-7951 or Celeste M. Murphy, Legal Branch Chief, at (202) 551-
3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Telecommunications