SEC Comment Letter 0000000000-23-008227 to PMGC Holdings Inc. (ELAB)
PMGC Holdings Inc.
Date: Aug. 1, 2023 · CIK: 0001840563 · Accession: 0000000000-23-008227
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Letter
United States securities and exchange commission logo August 1, 2023 Jordan Plews, Ph. D. Chief Executive Officer Elevai Labs Inc. 120 Newport Center Drive, Ste. 250 Newport Beach, CA 92660 Re:Elevai Labs Inc. Amendment No. 2 to Draft Registration Statement on Form S-1 Submitted July 25, 2023 CIK No. 0001840563 Dear Jordan Plews: We have reviewed your amended draft 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 providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. 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 the information you provide in response to this comment and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 2 to Draft Registration Statement on Form S-1 Submitted July 25, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 91 1.We note you have included a discussion of your results of operations for the three months ended March 31, 2023 compared to the three months ended March 31, 2022. However, it appears you have not included the discussion of your results of operations for the fiscal year ended December 31, 2022 compared to the fiscal year ended December 31, 2021 in this amendment. Please advise.
FirstName LastNameJordan Plews, Ph. D. Comapany NameElevai Labs Inc. August 1, 2023 Page 2 FirstName LastName Jordan Plews, Ph. D. Elevai Labs Inc. August 1, 2023 Page 2 You may contact Tracie Mariner at 202-551-3744 or Daniel Gordon at 202-551-3486 if you have questions regarding comments on the financial statements and related matters. Please contact Tyler Howes at 202-551-3370 or Joe McCann at 202-551-6262 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Tim Dockery, Esq.
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United States securities and exchange commission logo
August 1, 2023
Jordan Plews, Ph. D.
Chief Executive Officer
Elevai Labs Inc.
120 Newport Center Drive, Ste. 250
Newport Beach, CA 92660
Re:Elevai Labs Inc.
Amendment No. 2 to Draft Registration Statement on Form S-1
Submitted July 25, 2023
CIK No. 0001840563
Dear Jordan Plews:
We have reviewed your amended draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. 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 the information you provide in response to this comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 2 to Draft Registration Statement on Form S-1 Submitted July 25, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 91
1.We note you have included a discussion of your results of operations for the three months
ended March 31, 2023 compared to the three months ended March 31, 2022. However, it
appears you have not included the discussion of your results of operations for the fiscal
year ended December 31, 2022 compared to the fiscal year ended December 31, 2021 in
this amendment. Please advise.
FirstName LastNameJordan Plews, Ph. D.
Comapany NameElevai Labs Inc.
August 1, 2023 Page 2
FirstName LastName
Jordan Plews, Ph. D.
Elevai Labs Inc.
August 1, 2023
Page 2
You may contact Tracie Mariner at 202-551-3744 or Daniel Gordon at 202-551-3486 if
you have questions regarding comments on the financial statements and related matters. Please
contact Tyler Howes at 202-551-3370 or Joe McCann at 202-551-6262 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Tim Dockery, Esq.