SEC Comment Letter for AVITA Medical, Inc. (RCEL, AVHHL) (CIK 0001762303) (RCEL) — Sep 24, 2019
AVITA Medical, Inc. (RCEL, AVHHL) (CIK 0001762303)
Date: Sept. 24, 2019 · CIK: 0001762303 · Accession: 0000000000-19-013915
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-39059
Letter
September 24, 2019 Michael Perry Chief Executive Officer Avita Medical Limited Level 7, 330 Collins Street Melbourne VIC 3000 Australia Re:Avita Medical Limited Registration Statement on Form 20-F Filed September 19, 2019 File No. 001-39059 Dear Dr. Perry: We have reviewed your filing 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 these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response and any amendment you may file in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 18, 2019 letter. Registration Statement on Form 20-F filed September 19, 2019 Key Information, page 2 1.We note your response to prior comment 8, and your disclosure added on pages 4, 46 and 95 that the information in exhibit 15.1 should not be relied on as indicative of actual results for the year ended June 30, 2019. You may not disclaim responsibility for your disclosure; please revise to remove any implication to the contrary. Also: •If the exhibit is not intended to be indicative of actual results, clarify the purpose of the report included as an exhibit, including what it is intended to indicate. •Please be advised that you are responsible for considering whether additional disclosures of material information regarding your results are required to make the statements in your filing not misleading.
FirstName LastNameMichael Perry Comapany NameAvita Medical Limited September 24, 2019 Page 2 FirstName LastName Michael Perry Avita Medical Limited September 24, 2019 Page 2 General 2.Please ensure that your disclosure is current. We note for example your September 17, 2019 press release. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Michael Fay at (202) 551-3812 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 Tim Buchmiller at (202) 551-3635 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: Christopher H. Cunningham, Esq.
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September 24, 2019
Michael Perry
Chief Executive Officer
Avita Medical Limited
Level 7, 330 Collins Street
Melbourne VIC 3000 Australia
Re:Avita Medical Limited
Registration Statement on Form 20-F
Filed September 19, 2019
File No. 001-39059
Dear Dr. Perry:
We have reviewed your filing 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments. Unless we note otherwise, our references to prior
comments are to comments in our September 18, 2019 letter.
Registration Statement on Form 20-F filed September 19, 2019
Key Information, page 2
1.We note your response to prior comment 8, and your disclosure added on pages 4, 46 and
95 that the information in exhibit 15.1 should not be relied on as indicative of actual
results for the year ended June 30, 2019. You may not disclaim responsibility for your
disclosure; please revise to remove any implication to the contrary. Also:
•If the exhibit is not intended to be indicative of actual results, clarify the purpose of
the report included as an exhibit, including what it is intended to indicate.
•Please be advised that you are responsible for considering whether additional
disclosures of material information regarding your results are required to make the
statements in your filing not misleading.
FirstName LastNameMichael Perry
Comapany NameAvita Medical Limited
September 24, 2019 Page 2
FirstName LastName
Michael Perry
Avita Medical Limited
September 24, 2019
Page 2
General
2.Please ensure that your disclosure is current. We note for example your September 17,
2019 press release.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact Michael Fay at (202) 551-3812 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 Tim Buchmiller at (202) 551-3635 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: Christopher H. Cunningham, Esq.