SEC Comment Letter 0000000000-23-013545 to Advanced Biomed Inc. (ADVB)
Advanced Biomed Inc.
Date: Dec. 12, 2023 · CIK: 0001941029 · Accession: 0000000000-23-013545
AI Filing Summary & Sentiment
File numbers found in text: 333-272110
Letter
United States securities and exchange commission logo December 12, 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. 7 to Registration Statement on Form S-1 Filed December 5, 2023 File No. 333-272110 Dear Hung To Pau: 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. Unless we note otherwise, any references to prior comments are to comments in our November 30, 2023 letter. Amendment No. 7 to Form S-1 Exhibits 1.We note that you have included as Exhibit 8.1 the opinion of AllBright Law Offices, which is dated August 28, 2023, and that the opinion is "limited to PRC Laws of general application on the date hereof." We also note that your registration statement here contains updated disclosure regarding opinions you have received from AllBright Law Offices since your amendment filed on August 28, 2023, and subsequent amendments, such as with respect to the CSRC Trial Measures. Please provide an updated opinion and consent of counsel.
FirstName LastNameHung To Pau, Ph.D. Comapany NameAdvanced Biomed Inc. December 12, 2023 Page 2 FirstName LastName Hung To Pau, Ph.D. Advanced Biomed Inc. December 12, 2023 Page 2 Please 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
December 12, 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. 7 to Registration Statement on Form S-1
Filed December 5, 2023
File No. 333-272110
Dear Hung To Pau:
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. Unless we note otherwise,
any references to prior comments are to comments in our November 30, 2023 letter.
Amendment No. 7 to Form S-1
Exhibits
1.We note that you have included as Exhibit 8.1 the opinion of AllBright Law
Offices, which is dated August 28, 2023, and that the opinion is "limited to PRC Laws of
general application on the date hereof." We also note that your registration statement here
contains updated disclosure regarding opinions you have received from AllBright Law
Offices since your amendment filed on August 28, 2023, and subsequent amendments,
such as with respect to the CSRC Trial Measures. Please provide an updated opinion and
consent of counsel.
FirstName LastNameHung To Pau, Ph.D.
Comapany NameAdvanced Biomed Inc.
December 12, 2023 Page 2
FirstName LastName
Hung To Pau, Ph.D.
Advanced Biomed Inc.
December 12, 2023
Page 2
Please 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.