SEC Comment Letter for POMDOCTOR Ltd (POM) (CIK 0001877971) (POM) — Mar 24, 2025
POMDOCTOR Ltd (POM) (CIK 0001877971)
Date: March 24, 2025 · CIK: 0001877971 · Accession: 0000000000-25-003118
AI Filing Summary & Sentiment
File numbers found in text: 333-285771
Letter
March 24, 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 Registration Statement on Form F-1 Filed March 13, 2025 File No. 333-285771 Dear Zhenyang Shi: We have reviewed your registration statement and have the following comment(s). Please respond to this letter by amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Registration Statement on Form F-1 filed March 13, 2025 Capitalization, page 74 1.We note you removed short-term bank loans and loans from third parties from your capitalization table. Please revise to include all current indebtedness in your capitalization or explain the change. Refer to Item 3B of Form 20-F. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
March 24, 2025 Page 2 Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. 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
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March 24, 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
Registration Statement on Form F-1
Filed March 13, 2025
File No. 333-285771
Dear Zhenyang Shi:
We have reviewed your registration statement and have the following comment(s).
Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement on Form F-1 filed March 13, 2025
Capitalization, page 74
1.We note you removed short-term bank loans and loans from third parties from your
capitalization table. Please revise to include all current indebtedness in your
capitalization or explain the change. Refer to Item 3B of Form 20-F.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
March 24, 2025
Page 2
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
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