SEC Comment Letter for Atotech Ltd (CIK 0001762459) — Jan 19, 2021
Atotech Ltd (CIK 0001762459)
Date: Jan. 19, 2021 · CIK: 0001762459 · Accession: 0000000000-21-000605
AI Filing Summary & Sentiment
File numbers found in text: 333-235928
Letter
United States securities and exchange commission logo January 19, 2021 Geoff Wild Chief Executive Officer Atotech Ltd William Street, West Bromwich West Midlands, B70 0BG United Kingdom Re:Atotech Ltd Amendment No. 4 to Registration Statement on Form F-1 Filed January 11, 2021 File No. 333-235928 Dear Mr. Wild: 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. Amended Registration Statement on Form F-1 Exhibit Index Form of Opinion of Ogier, page II-3 1.Please have counsel revise the legal opinion to remove the assumption in paragraph 3(e) that the Selling Stockholders have sufficient Shares already in issue to be sold as part of the public offering. It is inappropriate for counsel to assume any of the material facts underlying the opinion. For more information refer to Section II.B.3.a. of Staff Legal Bulletin No. 19.
FirstName LastNameGeoff Wild Comapany NameAtotech Ltd January 19, 2021 Page 2 FirstName LastName Geoff Wild Atotech Ltd January 19, 2021 Page 2 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
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United States securities and exchange commission logo
January 19, 2021
Geoff Wild
Chief Executive Officer
Atotech Ltd
William Street, West Bromwich
West Midlands, B70 0BG
United Kingdom
Re:Atotech Ltd
Amendment No. 4 to
Registration Statement on Form F-1
Filed January 11, 2021
File No. 333-235928
Dear Mr. Wild:
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.
Amended Registration Statement on Form F-1
Exhibit Index
Form of Opinion of Ogier, page II-3
1.Please have counsel revise the legal opinion to remove the assumption in paragraph 3(e)
that the Selling Stockholders have sufficient Shares already in issue to be sold as part of
the public offering. It is inappropriate for counsel to assume any of the material facts
underlying the opinion. For more information refer to Section II.B.3.a. of Staff Legal
Bulletin No. 19.
FirstName LastNameGeoff Wild
Comapany NameAtotech Ltd
January 19, 2021 Page 2
FirstName LastName
Geoff Wild
Atotech Ltd
January 19, 2021
Page 2
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