SEC Comment Letter for POMDOCTOR Ltd (POM) (CIK 0001877971) (POM) — Jan 13, 2025
POMDOCTOR Ltd (POM) (CIK 0001877971)
Date: Jan. 13, 2025 · CIK: 0001877971 · Accession: 0000000000-25-000322
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January 13, 2025
Zhenyang Shi
Chairman and Chief Executive Officer
Pomdoctor Limited
Yongxu Industrial Park
No.19-23 Hejing Road, Dongsha Street
Liwan District, Guangzhou 510000
People’s Republic of China
Re:Pomdoctor Limited
Amendment No. 8 to Draft Registration Statement on Form F-1
Submitted December 23, 2024
CIK No. 0001877971
Dear Zhenyang Shi:
We have reviewed your amended draft registration statement and have the following
comment.
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 a 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 letter and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in
our November 27, 2024 letter.
Amendment No. 8 to Draft Registration Statement on Form F-1
Consolidated Financial Statements, page F-1
1.Please update your financial statements, or file as an exhibit to the filing the necessary
representations as to why such update is not necessary. Refer to Item 8.A.4 of Form
20-F and Instruction 2 thereto.
January 13, 2025
Page 2
Please contact Patrick Kuhn at 202-551-3308 or Joel Parker at 202-551-3651 if you
have questions regarding comments on the financial statements and related matters. Please
contact Scott Anderegg at 202-551-3342 or Dietrich King at 202-551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services