SEC Company Response from POMDOCTOR Ltd (POM) (CIK 0001877971) (POM) — Mar 31, 2025
POMDOCTOR Ltd (POM) (CIK 0001877971)
Date: March 31, 2025 · CIK: 0001877971 · Accession: 0001213900-25-026383
AI Filing Summary & Sentiment
File numbers found in text: 333-285771
Referenced dates: March 24, 2025
Letter
Office of Trade & Services Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: POMDOCTOR LIMITED (CIK No. 0001877971) Response to the Staff’s Comment on Registration Statement on Form F-1 (File No. 333-285771) Filed on March 13, 2025
Dear Mr. Kuhn, Mr. Parker, Mr. Anderegg, Mr. King:
On behalf of our client, POMDOCTOR LIMITED, a foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”), we are submitting to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) this letter setting forth the Company’s response to the comment contained in the Staff’s letter dated March 24, 2025 on the Company’s registration statement on Form F-1 filed on March 13, 2025 (the “Registration Statement”). Concurrently with the submission of this letter, the Company is filing its revised registration statement on Form F-1 (the “Revised Registration Statement”) and certain exhibits thereto via EDGAR with the Commission.
Set forth below is the Company’s response to the Staff’s comment. For convenience, the Staff’s comment is repeated below in bold, followed by the Company’s response to such comment.
Besides adding and revising disclosure in response to the Staff’s comment, the Company has also updated the Revised Registration Statement to include (i) its consolidated financial statements as of and for the year ended December 31, 2024, and (ii) other information and data to reflect recent developments.
Subject to market conditions and the review of the Staff, the Company plans to file an amendment to the Revised Registration Statement containing the estimated offering size and price range, and to commence marketing activities as soon as legally permissible. The Company would greatly appreciate the Staff’s continued assistance to meet this timeline.
Comment in Letter Dated March 24, 2025
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.
In response to the Staff’s comment, the Company has revised the disclosure on page 75 of the Revised Registration Statement.
* * *
If you have any questions regarding the Revised Registration Statement, please contact Steve Lin at steve.lin@hankunlaw.com, +86 10 8524 5826 (work) or +86 186 1049 5593 (cell).
Thank you for your time and attention.
Very truly yours,
/s/ Steve Lin
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CORRESP
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March 31, 2025
Mr. Patrick Kuhn
Mr. Joel Parker
Mr. Scott Anderegg
Mr. Dietrich King
Office of Trade & Services
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
POMDOCTOR LIMITED (CIK No. 0001877971)
Response to the Staff’s Comment on Registration Statement on Form F-1 (File No. 333-285771) Filed on March 13, 2025
Dear Mr. Kuhn, Mr. Parker, Mr. Anderegg, Mr. King:
On behalf of our client, POMDOCTOR
LIMITED, a foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”), we are
submitting to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
this letter setting forth the Company’s response to the comment contained in the Staff’s letter dated March 24, 2025 on the
Company’s registration statement on Form F-1 filed on March 13, 2025 (the “Registration Statement”). Concurrently
with the submission of this letter, the Company is filing its revised registration statement on Form F-1 (the “Revised Registration
Statement”) and certain exhibits thereto via EDGAR with the Commission.
Set forth below is the Company’s
response to the Staff’s comment. For convenience, the Staff’s comment is repeated below in bold, followed by the Company’s
response to such comment.
Besides adding and revising
disclosure in response to the Staff’s comment, the Company has also updated the Revised Registration Statement to include (i) its
consolidated financial statements as of and for the year ended December 31, 2024, and (ii) other information and data to reflect recent
developments.
Subject to market conditions and the review of the Staff, the Company
plans to file an amendment to the Revised Registration Statement containing the estimated offering size and price range, and to commence
marketing activities as soon as legally permissible. The Company would greatly appreciate the Staff’s continued assistance to meet
this timeline.
Comment in Letter Dated March 24, 2025
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.
In response to the Staff’s comment,
the Company has revised the disclosure on page 75 of the Revised Registration Statement.
* * *
If you have any questions
regarding the Revised Registration Statement, please contact Steve Lin at steve.lin@hankunlaw.com, +86 10 8524 5826 (work) or +86 186
1049 5593 (cell).
Thank you for your time and
attention.
Very truly yours,
/s/ Steve Lin
Steve Lin
c.c.
Zhenyang Shi, Chief Executive Officer, POMDOCTOR LIMITED
Li Xu, Chief Financial Officer, POMDOCTOR LIMITED
Steve Lin, Esq., Partner, Han Kun Law Offices
LLP
Dinglei Xiao, Partner, Marcum Asia CPAs LLP
Fang Liu, Esq., Partner, VCL Law LLP