SEC Comment Letter 0000000000-24-011828 to Ping An Biomedical Co., Ltd. (PASW)
Ping An Biomedical Co., Ltd.
Date: Oct. 22, 2024 · CIK: 0001897532 · Accession: 0000000000-24-011828
AI Filing Summary & Sentiment
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File numbers found in text: 333-282499
Letter
October 22, 2024 Suqin Li Chief Executive Officer Majestic Ideal Holdings Ltd 22/F, China United Plaza 1008, Tai Nan West Street Cheung Sha Wan, Kowloon, Hong Kong Re:Majestic Ideal Holdings Ltd Registration Statement on Form F-1 Filed October 4, 2024 File No. 333-282499 Dear Suqin Li: We have reviewed your registration statement and have the following comments. 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 October 4, 2024 Certain Relationships and Related Party Transactions, page 98 1.Please update your disclosure so that it reflects the related party transactions as of the date of the prospectus. Refer to Item 7.B of Form 20-F. Currently, your disclosure is as of March 31, 2024. General We note your disclosure in the Resale Prospectus Shareholders Plan of Distribution section that your selling shareholders may sell their securities through use of a broker- dealer. Please confirm your understanding that the retention by a selling shareholder of an underwriter would constitute a material change to your plan of distribution requiring a post-effective amendment. Please also revise to provide all required undertakings specified in Item 512 of Regulation S-K, including, but not limited to, 2.
October 22, 2024 Page 2 Item 512(a)(1)(iii) of Regulation S-K. 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. 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 Heather Clark at 202-551-3624 or Kevin Woody at 202-551-3629 if you have questions regarding comments on the financial statements and related matters. Please contact Thomas Jones at 202-551-3602 or Jay Ingram at 202-551-3397 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc:Lawrence S. Venick, Esq.
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October 22, 2024
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Registration Statement on Form F-1
Filed October 4, 2024
File No. 333-282499
Dear Suqin Li:
We have reviewed your registration statement and have the following comments.
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 October 4, 2024
Certain Relationships and Related Party Transactions, page 98
1.Please update your disclosure so that it reflects the related party transactions as of the
date of the prospectus. Refer to Item 7.B of Form 20-F. Currently, your disclosure is
as of March 31, 2024.
General
We note your disclosure in the Resale Prospectus Shareholders Plan of Distribution
section that your selling shareholders may sell their securities through use of a broker-
dealer. Please confirm your understanding that the retention by a selling shareholder
of an underwriter would constitute a material change to your plan of distribution
requiring a post-effective amendment. Please also revise to provide all required
undertakings specified in Item 512 of Regulation S-K, including, but not limited to, 2.
October 22, 2024
Page 2
Item 512(a)(1)(iii) of Regulation S-K.
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.
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 Heather Clark at 202-551-3624 or Kevin Woody at 202-551-3629 if
you have questions regarding comments on the financial statements and related
matters. Please contact Thomas Jones at 202-551-3602 or Jay Ingram at 202-551-3397 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Lawrence S. Venick, Esq.