Correspondence 0001213900-23-071443 from Meihua International Medical Technologies Co., Ltd. (MHUA) (CIK 0001835615) (MHUAF)
Meihua International Medical Technologies Co., Ltd. (MHUA) (CIK 0001835615)
Date: Aug. 29, 2023 · CIK: 0001835615 · Accession: 0001213900-23-071443
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File numbers found in text: 001-41291
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Meihua International Medical Technologies Co.,
Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
August 29, 2023
Division of Corporation Finance
Office of Industrial Applications and Services
U.S. Securities and Exchange Commission
Washington, D.C. 20549
Attn:
Mr. Conlon Danberg
Ms. Margaret Schwartz
Re:
Meihua International Medical Technologies Co., Ltd.
Amendment No. 2 to Annual Report on Form 20-F
Filed August 21, 2023
File No. 001-41291
Ladies and Gentlemen:
We are hereby
transmitting the response of Meihua International Medical Technologies Co., Ltd., a Cayman company (the
“Company,” “we,” or “our”), to the comment letter we
received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the
“Commission”) on August 25, 2023, regarding the Company’s Amendment No. 2 to our Annual Report on
Form 20-F filed with the Commission on August 21, 2023. An Amendment No. 3 to the Form 20-F (the “Amended No.3 to Form
20-F”) is being submitted to the Commission concurrently with this letter.
For your convenience, we have
repeated below the comments of the Staff in bold and have followed the Staff’s comments with the Company’s response.
Amendment No. 2 to Annual Report on Form
20-F, filed August 21, 2023
Item 3. Key Information, page 1
1. We note the changes you made to your disclosure
appearing in the Risk Factors section of your amended annual report for the fiscal year ended December 31, 2022 relating to legal and
operational risks associated with operating in China and PRC regulations. The annual report discloses information as of your fiscal year
ended December 31, 2022 and it is unclear to us that there were changes in the regulatory environment in the PRC for the period covered
by the report warranting revised disclosure to mitigate the challenges you face and related disclosures. The Sample Letters to China-Based
Companies sought specific disclosure relating to the risk that the PRC government may intervene in or influence your operations at any
time, or may exert control over operations of your business, which could result in a material change in your operations and/or the value
of the securities you have registered for sale. We remind you that, pursuant to federal securities rules, the term “control”
(including the terms “controlling,” “controlled by,” and “under common control with”) as defined in
Securities Act Rule 405 means “the possession, direct or indirect, of the power to direct or cause the direction of the management
and policies of a person, whether through the ownership of voting securities, by contract, or otherwise.” The Sample Letters also
sought specific disclosures relating to uncertainties regarding the enforcement of laws and that the rules and regulations in China can
change quickly with little advance notice. Because your revised disclosure has removed references to the PRC government’s power
to exercise significant oversight and discretion over the conduct of your business, the level of government involvement in the Chinese
economy, and the risk factors captioned “PRC’s economic, political and social conditions, as well as changes in any government
policies, laws and regulations, could have a material adverse effect on our business” and “Uncertainties with respect to the
PRC legal system could adversely affect us,” we do not believe that your revised disclosure conveys these risks. We also note that
your disclosure in the “Key Information Related to Doing Business in China” section at the outset of Item 3 continues to reference
the risk factors that were removed in your latest amendment. We further note your revision noting that you may not be able to effectively
protect your intellectual property rights or to enforce your contractual rights in China “or in other jurisdictions.” However,
you disclose that Meihua is not a Chinese operating company but a Cayman Islands holding company with all operations conducted by its
subsidiaries located in mainland China. Please disclose the other jurisdictions where you hold intellectual property. Please restore your
disclosures in these areas to the disclosures as they existed in your annual report as of July 3, 2023.
Response: We respectfully acknowledge
the Staff’s comment and the requirements stated in the Sample Letters to China-Based Companies. In response to the
Staff’s comment, we confirm that the Company is not a Chinese operating company but a Cayman Islands holding company with all
operations conducted by its subsidiaries located in mainland China. Accordingly, we restored our disclosures in our Amendment No. 3
to Form 20-F in the areas the Staff mentioned in their comment letter to the disclosures as they existed in our annual report as
filed with the Commission on July 3, 2023.
We thank the Staff in advance
for its review of the foregoing in relation to the Company’s filing of its Amended No. 3 to Form 20-F. Should you have any questions
or concerns, please kindly contact our counsel, Megan J. Penick, Esq. of Michelman & Robinson, LLP, by telephone at (646) 320-4104
or mpenick@mrllp.com.
Sincerely,
/s/ Xin Wang
Xin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.