SEC Comment Letter for POMDOCTOR Ltd (POM) (CIK 0001877971) (POM) — Jul 24, 2025
POMDOCTOR Ltd (POM) (CIK 0001877971)
Date: July 24, 2025 · CIK: 0001877971 · Accession: 0000000000-25-007823
AI Filing Summary & Sentiment
File numbers found in text: 333-285771
Letter
July 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 Amendment No. 3 to Registration Statement on Form F-1 Filed July 15, 2025 File No. 333-285771 Dear Zhenyang Shi: We have reviewed your amended registration statement and have the following comment. 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. Amendment No. 3 to Registration Statement on Form F-1 filed July 15, 2025 Cover Page 1.We note your revised disclosure that six ADS will represent one class A ordinary shares. As such, it appears an investor could purchase a numbers of ADSs that is not divisible by six, and that purchase would result in the investor having a fractional interest in an ordinary share. Please revise your disclosure to address the material aspects of any such fractional interests.
July 24, 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
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July 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
Amendment No. 3 to Registration Statement on Form F-1
Filed July 15, 2025
File No. 333-285771
Dear Zhenyang Shi:
We have reviewed your amended registration statement and have the following
comment.
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.
Amendment No. 3 to Registration Statement on Form F-1 filed July 15, 2025
Cover Page
1.We note your revised disclosure that six ADS will represent one class A ordinary
shares. As such, it appears an investor could purchase a numbers of ADSs that is not
divisible by six, and that purchase would result in the investor having a fractional
interest in an ordinary share. Please revise your disclosure to address the material
aspects of any such fractional interests.
July 24, 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