CORRESP Filing
BGM Group Ltd.
Date: May 8, 2025 · CIK: 0001779578 · Accession: 0001104659-25-045899
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-3
Letter
VIA EDGAR Division of Corporation Finance Office of Life Sciences Washington, DC 20549 Re: BGM Group Ltd Form 20-F for Fiscal Year Ended September 30, 2024 Correspondence from the SEC on April 25, 2025 File No. 001-3 9805
Dear Ms. Lynn Dicker / Ms. Tara Harkins / Mr. Daniel Crawford / Mr. Tim Buchmiller:
BGM Group Ltd (the " Company ", " we ", " us " or " our ") hereby transmits its response to the letter received from the staff (the " Staff ") of the U.S. Securities and Exchange Commission (the " SEC "), dated April 25, 2025, with respect to Amendment No. 2 to its annual report on Form 20-F filed on April 3, 2025 (the " Form 20-F ").
Concurrently with the submission of this letter, the Company is submitting its Amendment No. 3 to the Form 20-F (the " Amended Form 20-F "), which reflects the Company's responses to the comments received from the Staff and certain updated information. For ease of reference, we have included the Staff's comment in bold, and the Company's response is set forth immediately below the comment.
Amendment No. 2 to Annual Report on Form 20-F for Fiscal Year Ended September 30, 2024
Item 4. Information on the Company
Facilities, page 78
1. We note your response to prior comment 2 and reissue the comment in part. We note your revised disclosure on page 100 that you "made the decision to shut down a production factory of Chengdu Qilianshan Biotechnology Co., Ltd. which occupied 78% of the Company's total Heparin products to reduce losses." Please revise to disclose the reason for constructing the new facility in Chongqing city for production of your heparin products when you have ceased heparin production at your primary facility. We also note your revised disclosure that the Shengfu Production Line appears to be located in Chongqing province and does not appear in your table on page 79. Please revise your table to disclose the property, or otherwise advise.
Response : The Company respectfully acknowledges the Staff's comment and has amended the disclosure on page 79 and 100 of the Amended Form 20-F in response to the Staff's comment.
* * *
We thank the Staff for its review of the foregoing. If you have questions or further comments, please forward them by electronic mail to Mr. Chen Xin at xinchen@qiliancorp.com or by telephone at +86 028-6477-5180.
Very truly yours,
/s/ Chen
Xin
Show Raw Text
CORRESP 1 filename1.htm BGM Group Ltd No. 152 Hongliang East 1st Street, No. 1703 Tianfu New District, Chengdu, 610200 People's Republic of China May 8 , 2025 VIA EDGAR Ms. Lynn Dicker Ms. Tara Harkins Mr. Daniel Crawford Mr. Tim Buchmiller U.S. Securities and Exchange Commission Division of Corporation Finance Office of Life Sciences 100 F Street, N.E. Mail Stop 4631 Washington, DC 20549 Re: BGM Group Ltd Form 20-F for Fiscal Year Ended September 30, 2024 Correspondence from the SEC on April 25, 2025 File No. 001-3 9805 Dear Ms. Lynn Dicker / Ms. Tara Harkins / Mr. Daniel Crawford / Mr. Tim Buchmiller: BGM Group Ltd (the " Company ", " we ", " us " or " our ") hereby transmits its response to the letter received from the staff (the " Staff ") of the U.S. Securities and Exchange Commission (the " SEC "), dated April 25, 2025, with respect to Amendment No. 2 to its annual report on Form 20-F filed on April 3, 2025 (the " Form 20-F "). Concurrently with the submission of this letter, the Company is submitting its Amendment No. 3 to the Form 20-F (the " Amended Form 20-F "), which reflects the Company's responses to the comments received from the Staff and certain updated information. For ease of reference, we have included the Staff's comment in bold, and the Company's response is set forth immediately below the comment. Amendment No. 2 to Annual Report on Form 20-F for Fiscal Year Ended September 30, 2024 Item 4. Information on the Company Facilities, page 78 1. We note your response to prior comment 2 and reissue the comment in part. We note your revised disclosure on page 100 that you "made the decision to shut down a production factory of Chengdu Qilianshan Biotechnology Co., Ltd. which occupied 78% of the Company's total Heparin products to reduce losses." Please revise to disclose the reason for constructing the new facility in Chongqing city for production of your heparin products when you have ceased heparin production at your primary facility. We also note your revised disclosure that the Shengfu Production Line appears to be located in Chongqing province and does not appear in your table on page 79. Please revise your table to disclose the property, or otherwise advise. Response : The Company respectfully acknowledges the Staff's comment and has amended the disclosure on page 79 and 100 of the Amended Form 20-F in response to the Staff's comment. * * * 1 We thank the Staff for its review of the foregoing. If you have questions or further comments, please forward them by electronic mail to Mr. Chen Xin at xinchen@qiliancorp.com or by telephone at +86 028-6477-5180. Very truly yours, /s/ Chen Xin Name: Chen Xin Title: Chief Executive Officer 2