Correspondence 0001193125-24-265673 from Burning Rock Biotech Ltd (BNR)
Burning Rock Biotech Ltd
Date: Nov. 26, 2024 · CIK: 0001792267 · Accession: 0001193125-24-265673
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-39316
Referenced dates: October 31, 2024
Letter
VIA EDGAR Division of Corporation Finance Office of Industrial Applications and Services Washington, D.C. Re: Burning Rock Biotech Limited Form 20-F for Fiscal Year Ended December 31, 2023 File No. 001-39316
Dear Ms. Wong and Ms. Xiao:
On behalf of our client, Burning Rock Biotech Limited (the “Company”), we are responding to the comment from the staff of the Securities and Exchange Commission (the “Staff”) contained in its letter dated October 31, 2024 regarding the Company’s Form 20-F for the fiscal year ended December 31, 2023 filed on April 29, 2024 (the “Form 20-F”). The Staff’s comment is repeated below in bold and is followed by the Company’s response.
Form 20-F for the Fiscal Year Ended December 31, 2023
Item 18. Exhibits
Exhibits 12.1 and 12.2, page 137
1. We note you have omitted the portion of introductory language in paragraph 4, as well as language in paragraph 4(b) of the Section 302 certifications, which refers to the certifying officers’ responsibility for designing, establishing and maintaining internal control over financial reporting for the company. Since you are subject to the internal control over financial reporting requirements, please amend your Form 20-F accordingly to include the requisite language in your Section 302 certifications. Refer to
Exchange Act Rule 13a-14(a) and Item 601(b)(31) of Regulation S-K. You may file an abbreviated amendment that is limited to the cover page, explanatory note, signature page and paragraphs 1, 2, 4 and 5 of the certification. Please ensure the revised certifications refer to the Form 20-F/A and are currently dated.
In response to the Staff’s comment, the Company has filed an amendment to the Form 20-F which includes the revised officers’ certifications. This amendment includes only the cover page, the explanatory note, the exhibit index, the signature page and the revised officers’ certifications containing paragraphs 1, 2, 4 and 5.
Should you have any questions about the responses contained herein, please contact the undersigned by phone at +852-2532-3783 or via e-mail at szhao@cgsh.com.
Very truly yours,
CLEARY GOTTLIEB STEEN & HAMILTON LLP
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CORRESP 1 filename1.htm CORRESP November 26, 2024 VIA EDGAR Christie Wong Li Xiao Division of Corporation Finance Office of Industrial Applications and Services U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Burning Rock Biotech Limited Form 20-F for Fiscal Year Ended December 31, 2023 File No. 001-39316 Dear Ms. Wong and Ms. Xiao: On behalf of our client, Burning Rock Biotech Limited (the “Company”), we are responding to the comment from the staff of the Securities and Exchange Commission (the “Staff”) contained in its letter dated October 31, 2024 regarding the Company’s Form 20-F for the fiscal year ended December 31, 2023 filed on April 29, 2024 (the “Form 20-F”). The Staff’s comment is repeated below in bold and is followed by the Company’s response. Form 20-F for the Fiscal Year Ended December 31, 2023 Item 18. Exhibits Exhibits 12.1 and 12.2, page 137 1. We note you have omitted the portion of introductory language in paragraph 4, as well as language in paragraph 4(b) of the Section 302 certifications, which refers to the certifying officers’ responsibility for designing, establishing and maintaining internal control over financial reporting for the company. Since you are subject to the internal control over financial reporting requirements, please amend your Form 20-F accordingly to include the requisite language in your Section 302 certifications. Refer to Exchange Act Rule 13a-14(a) and Item 601(b)(31) of Regulation S-K. You may file an abbreviated amendment that is limited to the cover page, explanatory note, signature page and paragraphs 1, 2, 4 and 5 of the certification. Please ensure the revised certifications refer to the Form 20-F/A and are currently dated. In response to the Staff’s comment, the Company has filed an amendment to the Form 20-F which includes the revised officers’ certifications. This amendment includes only the cover page, the explanatory note, the exhibit index, the signature page and the revised officers’ certifications containing paragraphs 1, 2, 4 and 5. 2 Should you have any questions about the responses contained herein, please contact the undersigned by phone at +852-2532-3783 or via e-mail at szhao@cgsh.com. Very truly yours, CLEARY GOTTLIEB STEEN & HAMILTON LLP By: /s/ Shuang ZHAO Shuang ZHAO, a Partner cc: Mr. Yusheng Han, Chairman of the Board of Directors and Chief Executive Officer Ms. Xiaozhi Hu, Senior Director in Finance Burning Rock Biotech Limited