Correspondence 0001493152-23-007812 from CytoMed Therapeutics Ltd (GDTC)
CytoMed Therapeutics Ltd
Date: March 15, 2023 · CIK: 0001873093 · Accession: 0001493152-23-007812
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File numbers found in text: 333-268456
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CytoMed
Therapeutics Limited
1
Commonwealth Lane
#08-22
Singapore
149544
+65
6250 7738
VIA
EDGAR
March
15, 2023
U.S.
Securities & Exchange Commission
Division
of Corporation Finance
Office
of Life Sciences
100
F Street, NE
Washington,
D.C. 20549
Attn:
Tracie Mariner
Re:
CytoMed Therapeutics Limited
(f/k/a
CytoMed Therapeutics Pte. Ltd.)
Amendment
No. 2 to Registration Statement on Form F-1
Filed
February 21, 2023
File
No. 333-268456
Dear
Ms. Mariner:
CytoMed
Therapeutics Limited (the “Company,” “we,” “our” or “us”)
hereby transmits our response to the comment letter received from the staff (the “Staff,” “you”
or “your”) of the U.S. Securities and Exchange Commission (the “Commission”), on February 24, 2023,
regarding Amendment No.2 to Registration Statement on Form F-1 submitted to the Commission on February 21, 2023.
For
your convenience, we have repeated below your comments in bold, and have followed each comment with our response. Disclosure changes
made in response to the Staff’s comments have been made in Amendment No. 3 to the Registration Statement (the “Amendment”),
which is being submitted to the Commission contemporaneously with the submission of this letter.
Amendment
No. 2 to Registration Statement on Form F-1
Business
Overview,
page 89
1. We
note the revisions to the pipeline on page 90, so that there are now four columns prior to
Phase 1: discovery, process development, preclinical studies, and trial application. Revise
the pipeline table to combine these four columns into no more than two columns, each no wider
or more prominent than each of the phases of clinical development. Also revise the table
so that each row has one arrow that begins on the left and progresses to the point of current
development, rather than multiple arrows within each column.
Response:
The Company respectfully acknowledges the Staff’s comment and has revised page 90 of the Amendment accordingly.
***
We
thank you for your review of the foregoing. If you have further comments, please feel free to contact to our counsel, Richard I. Anslow,
Esq., at ranslow@egsllp.com or by telephone at (212) 370-1300.
Sincerely,
/s/
Chee Kong CHOO
Chee
Kong CHOO
Director
and Chairman
cc:
Richard
I. Anslow, Esq.
Ellenoff
Grossman & Schole LLP