SEC Comment Letter for Aesthetic Medical International Holdings Group Ltd (PAIYY) (CIK 0001757143) (PAIYY) — Sep 16, 2019
Aesthetic Medical International Holdings Group Ltd (PAIYY) (CIK 0001757143)
Date: Sept. 16, 2019 · CIK: 0001757143 · Accession: 0000000000-19-013608
AI Filing Summary & Sentiment
Letter
September 13, 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. 3 to Draft Registration Statement on Form F-1 Submitted September 3, 2019 CIK No. 0001757143 Dear Dr. Pengwu: We have reviewed your amended draft registration statement and have the following comment. 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 comment applies 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. 3 to Draft Registration Statement on Form F-1 Financial Statements Unaudited Interim Condensed Consolidated Statements of Comprehensive Income, page F-90 1.We note the pro forma earnings per share disclosure on page F-103. Please present on the face of your historic interim period income statement, pro forma earnings per share to give effect to the conversion of the Series A preferred shares.
FirstName LastNameZhou Pengwu Comapany NameAesthetic Medical International Holdings Group Ltd. September 13, 2019 Page 2 FirstName LastName Zhou Pengwu Aesthetic Medical International Holdings Group Ltd. September 13, 2019 Page 2 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 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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September 13, 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. 3 to
Draft Registration Statement on Form F-1
Submitted September 3, 2019
CIK No. 0001757143
Dear Dr. Pengwu:
We have reviewed your amended draft registration statement and have the following
comment.
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 comment applies 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. 3 to Draft Registration Statement on Form F-1
Financial Statements
Unaudited Interim Condensed Consolidated Statements of Comprehensive Income, page F-90
1.We note the pro forma earnings per share disclosure on page F-103. Please present on the
face of your historic interim period income statement, pro forma earnings per share to give
effect to the conversion of the Series A preferred shares.
FirstName LastNameZhou Pengwu
Comapany NameAesthetic Medical International Holdings Group Ltd.
September 13, 2019 Page 2
FirstName LastName
Zhou Pengwu
Aesthetic Medical International Holdings Group Ltd.
September 13, 2019
Page 2
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
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