SEC Company Response from POMDOCTOR Ltd (POM) (CIK 0001877971) (POM) — Sep 26, 2025
POMDOCTOR Ltd (POM) (CIK 0001877971)
Date: Sept. 26, 2025 · CIK: 0001877971 · Accession: 0001213900-25-092304
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File numbers found in text: 001-42749, 333-285771
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CORRESP
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filename1.htm
September 26, 2025
VIA EDGAR
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)
Registration Statement on Form F-1 (File No.
333-285771)
Registration Statement on Form 8-A (File No.
001-42749)
Ladies and Gentlemen:
In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, POMDOCTOR LIMITED (the “Company”)
hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1, as amended (the “Form F-1
Registration Statement”) be accelerated to and that the Form F-1 Registration Statement become effective at 4:00 p.m., Eastern
Time, on September 30, 2025, or as soon thereafter as practicable.
The Company also requests
that the Registration Statement on Form 8-A under the Securities Exchange Act of 1934, as amended, covering the American depositary
shares representing Class A ordinary shares of the Company, be declared effective concurrently with the Form F-1 Registration
Statement (the Form F-1 Registration Statement, together with the Registration Statement on Form 8-A, the “Registration
Statements”).
If there is any change in
the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may be making
an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461. The request may
be made by an executive officer of the Company or by any attorney from the Company’s U.S. counsel, Han Kun Law Offices LLP.
The Company understands that
the representative of the underwriters of the offering has joined in this request in a separate letter filed with the Securities and Exchange
Commission today.
[Signature page follows]
Very truly yours,
POMDOCTOR LIMITED
By:
/s/ Zhenyang Shi
Name:
Zhenyang Shi
Title:
Chairman and Chief Executive Officer