SEC Comment Letter 0000000000-23-009975 to Advanced Biomed Inc. (ADVB)
Advanced Biomed Inc.
Date: Sept. 8, 2023 · CIK: 0001941029 · Accession: 0000000000-23-009975
AI Filing Summary & Sentiment
File numbers found in text: 333-272110
Referenced dates: December 27, 2022, March 17, 2023
Letter
United States securities and exchange commission logo September 8, 2023 Hung To Pau, Ph.D. Chief Executive Officer Advanced Biomed Inc. 689-87 Xiaodong Road Yongkang District Tainan, Taiwan Re:Advanced Biomed Inc. Amendment No. 4 to Registration Statement on Form S-1 Filed August 28, 2023 File No. 333-272110 Dear Hung To Pau: We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply 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 these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 25, 2023 letter. Form S-1/A Filed August 28, 2023 China's Cancer Early Screening Market, page 69 1.We reference comment 27 from our comment letter dated December 27, 2022 and note your statement that "China’s early screening market is growing steadily, and the scale is expected to exceed USD 23.6 billion in three years." Please revise to cite the source of this estimate or expectation and explain the basis therefor. Enforceability of Civil Liabilities, page 123 2.We reference comment 17 from our comment letter dated March 17, 2023. Please revise to state the jurisdiction where each of the Company's directors are located.
FirstName LastNameHung To Pau, Ph.D. Comapany NameAdvanced Biomed Inc. September 8, 2023 Page 2 FirstName LastName Hung To Pau, Ph.D. Advanced Biomed Inc. September 8, 2023 Page 2 Financial Statements, page F-1 3.Please update your financial statements and corresponding financial information to include audited financial statements for the year ended June 30, 2023. Refer to Rule 8-08 of Regulation S-X. You may contact Nudrat Salik at 202-551-3692 or Al Pavot at 202-551-3738 if you have questions regarding comments on the financial statements and related matters. Please contact Benjamin Richie at 202-551-7857 or Margaret Schwartz at 202-551-7153 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc: Fang Liu, Esq.
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United States securities and exchange commission logo
September 8, 2023
Hung To Pau, Ph.D.
Chief Executive Officer
Advanced Biomed Inc.
689-87 Xiaodong Road
Yongkang District
Tainan, Taiwan
Re:Advanced Biomed Inc.
Amendment No. 4 to Registration Statement on Form S-1
Filed August 28, 2023
File No. 333-272110
Dear Hung To Pau:
We have reviewed your amended registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our August 25, 2023 letter.
Form S-1/A Filed August 28, 2023
China's Cancer Early Screening Market, page 69
1.We reference comment 27 from our comment letter dated December 27, 2022 and
note your statement that "China’s early screening market is growing steadily, and the scale
is expected to exceed USD 23.6 billion in three years." Please revise to cite the source of
this estimate or expectation and explain the basis therefor.
Enforceability of Civil Liabilities, page 123
2.We reference comment 17 from our comment letter dated March 17, 2023. Please revise
to state the jurisdiction where each of the Company's directors are located.
FirstName LastNameHung To Pau, Ph.D.
Comapany NameAdvanced Biomed Inc.
September 8, 2023 Page 2
FirstName LastName
Hung To Pau, Ph.D.
Advanced Biomed Inc.
September 8, 2023
Page 2
Financial Statements, page F-1
3.Please update your financial statements and corresponding financial information to
include audited financial statements for the year ended June 30, 2023. Refer to Rule 8-08
of Regulation S-X.
You may contact Nudrat Salik at 202-551-3692 or Al Pavot at 202-551-3738 if you have
questions regarding comments on the financial statements and related matters. Please contact
Benjamin Richie at 202-551-7857 or Margaret Schwartz at 202-551-7153 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc: Fang Liu, Esq.