SEC Comment Letter for Betterware de Mexico, S.A.B. de C.V. (BWMX) (CIK 0001788257) (BWMX) — Jan 9, 2020
Betterware de Mexico, S.A.B. de C.V. (BWMX) (CIK 0001788257)
Date: Jan. 9, 2020 · CIK: 0001788257 · Accession: 0000000000-20-000239
AI Filing Summary & Sentiment
File numbers found in text: 333-233982
Letter
January 9, 2020 Andres Campos Chief Executive Officer Betterware de Mexico, S.A. de C.V. Luis Enrique Williams 549 Colonia Belenes Norte Zapopan, Jalisco, 45145, México Re:Betterware de Mexico, S.A. de C.V. Amendment No. 3 to Registration Statement on Form F-4 Filed January 7, 2020 File No. 333-233982 Dear Mr. Campos: We have reviewed your amended registration statement and have the following comment. In our comment, 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 comment applies 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 this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our January 2, 2020 letter. Amendment No. 3 to Registration Statement on Form F-4 filed January 7, 2020 Recent Developments Related to Betterware Launch of web app platform, page 26 1.We note your response to comment 2, and your amended disclosure that "Betterware will deliver goods through its distribution network by connecting clients that want to purchase products directly through the web app platform to Betterware's distribution network via the globalization of the potential clients and the distribution network." It is unclear from this statement how the web app platform connects the consumer directly with Betterware's network of distributors. Please amend your filing to explain how the app connects consumers to the distribution network. For example, disclose whether all distributors
FirstName LastNameAndres Campos Comapany NameBetterware de Mexico, S.A. de C.V. January 9, 2020 Page 2 FirstName LastName Andres Campos Betterware de Mexico, S.A. de C.V. January 9, 2020 Page 2 have access to the app, and the mechanism by which Betterware determines how and through which distributors it will deliver goods purchased by consumers. Please contact Katherine Bagley at (202) 551-2545 or Lilyanna Peyser at (202) 551- 3222 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Jason Simon
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January 9, 2020
Andres Campos
Chief Executive Officer
Betterware de Mexico, S.A. de C.V.
Luis Enrique Williams 549
Colonia Belenes Norte
Zapopan, Jalisco, 45145, México
Re:Betterware de Mexico, S.A. de C.V.
Amendment No. 3 to Registration Statement on Form F-4
Filed January 7, 2020
File No. 333-233982
Dear Mr. Campos:
We have reviewed your amended registration statement and have the following
comment. In our comment, 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 comment applies 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 this comment, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our January 2, 2020 letter.
Amendment No. 3 to Registration Statement on Form F-4 filed January 7, 2020
Recent Developments Related to Betterware
Launch of web app platform, page 26
1.We note your response to comment 2, and your amended disclosure that "Betterware will
deliver goods through its distribution network by connecting clients that want to purchase
products directly through the web app platform to Betterware's distribution network via
the globalization of the potential clients and the distribution network." It is unclear from
this statement how the web app platform connects the consumer directly with Betterware's
network of distributors. Please amend your filing to explain how the app connects
consumers to the distribution network. For example, disclose whether all distributors
FirstName LastNameAndres Campos
Comapany NameBetterware de Mexico, S.A. de C.V.
January 9, 2020 Page 2
FirstName LastName
Andres Campos
Betterware de Mexico, S.A. de C.V.
January 9, 2020
Page 2
have access to the app, and the mechanism by which Betterware determines how and
through which distributors it will deliver goods purchased by consumers.
Please contact Katherine Bagley at (202) 551-2545 or Lilyanna Peyser at (202) 551-
3222 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Jason Simon