SEC Comment Letter for Atotech Ltd (CIK 0001762459) — Jan 9, 2020
Atotech Ltd (CIK 0001762459)
Date: Jan. 9, 2020 · CIK: 0001762459 · Accession: 0000000000-20-000207
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Letter
January 8, 2020 Geoff Wild Chief Executive Officer Atotech Ltd William Street, West Bromwich West Midlands, B70 0BG United Kingdom Re:Atotech Ltd Amendment No. 4 to Draft Registration Statement on Form F-1 Submitted December 30, 2019 CIK No. 0001762459 Dear Mr. Wild: 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 Summary Historical and Pro Forma Financial Information, page 21 1.Given the reclassifications that you made to your Consolidated Balance Sheet as of September 30, 2019, please revise the Non-current assets, Total assets, and Total liabilities line items in the balance sheet data section of your table to agree with the corresponding line items on your Consolidated Balance Sheet. This comment also applies to the Selected Historical Financial Information on page 68.
FirstName LastNameGeoff Wild Comapany NameAtotech Ltd January 8, 2020 Page 2 FirstName LastName Geoff Wild Atotech Ltd January 8, 2020 Page 2 Management Compensation, page 130 2.Please revise your disclosure in this section to include your most recently completed fiscal year. Please refer to Section I.6.B. of Form 20-F. You may contact Dale Welcome at 202-551-3865 or John Cash at 202-551-3768 if you have questions regarding comments on the financial statements and related matters. Please contact Erin Purnell at 202-551-3454 or Jay Ingram at 202-551-3397 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Patrick H. Shannon
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January 8, 2020
Geoff Wild
Chief Executive Officer
Atotech Ltd
William Street, West Bromwich
West Midlands, B70 0BG
United Kingdom
Re:Atotech Ltd
Amendment No. 4 to
Draft Registration Statement on Form F-1
Submitted December 30, 2019
CIK No. 0001762459
Dear Mr. Wild:
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
Summary Historical and Pro Forma Financial Information, page 21
1.Given the reclassifications that you made to your Consolidated Balance Sheet as of
September 30, 2019, please revise the Non-current assets, Total assets, and Total
liabilities line items in the balance sheet data section of your table to agree with the
corresponding line items on your Consolidated Balance Sheet. This comment also applies
to the Selected Historical Financial Information on page 68.
FirstName LastNameGeoff Wild
Comapany NameAtotech Ltd
January 8, 2020 Page 2
FirstName LastName
Geoff Wild
Atotech Ltd
January 8, 2020
Page 2
Management
Compensation, page 130
2.Please revise your disclosure in this section to include your most recently completed fiscal
year. Please refer to Section I.6.B. of Form 20-F.
You may contact Dale Welcome at 202-551-3865 or John Cash at 202-551-3768 if you
have questions regarding comments on the financial statements and related matters. Please
contact Erin Purnell at 202-551-3454 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Patrick H. Shannon