Correspondence 0001575872-23-001671 from Advanced Biomed Inc. (ADVB)
Advanced Biomed Inc.
Date: Oct. 27, 2023 · CIK: 0001941029 · Accession: 0001575872-23-001671
AI Filing Summary & Sentiment
File numbers found in text: 333-272110
Referenced dates: December 27, 2022, March 17, 2023, September 8, 2023
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Corporate Finance Amendment No. 4 to Registration Statement on Form S-1 Filed August 28, 2023 File No. 333-272110
Re: Advanced Biomed Inc.
Dear Mr. Richie,
Advanced Biomed Inc. (the “Company”) submit this letter in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in its letter dated September 8, 2023, relating to the above referenced Amendment No. 4 to Registration Statement on Form S-1 (“Amendment No. 4”). The Company is concurrently submitting an amendment to the Registration Statement (the “Amendment No. 5”).
For the Staff’s convenience, the Staff’s comments have been stated below in their entirety in bold, followed by the corresponding responses from the Company. Except for any page references appearing in the headings or the Staff’s comments (which are references to Amendment No. 4), all page references herein correspond to the page of the Amendment No. 5. Capitalized terms used but not defined in this letter have the meanings ascribed to such terms in the Amendment No. 5.
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.
Response: In response to the Staff’s comment, we have consolidated the industry and market data using the Grand View report commissioned by us and revised the disclosure on page 69.
Enforceability of Civil Liabilities, page
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.
Response: In response to the Staff’s comment, we have disclosed the jurisdictions where each of our directors and director nominees are located on page 123.
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.
Response: We have updated the registration statement to include audited financial statements for the year ended June 30, 2023.
We thank the Staff for its review of the foregoing. If you have any questions regarding this matter, please do not hesitate to contact Fang Liu at VCL Law LLP at fliu@vcllegal.com or by telephone at (703) 919-7285.
Very truly yours,
/s/ Hung To Pau
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October 27, 2023
VIA EDGAR
Benjamin Richie
United States Securities and Exchange Commission
Division of Corporate Finance
100 F. Street, N.E.
Washington, D.C. 20549
Re: Advanced Biomed Inc.
Amendment No. 4 to Registration Statement
on Form S-1
Filed August 28, 2023
File No. 333-272110
Dear Mr. Richie,
Advanced Biomed Inc. (the “Company”)
submit this letter in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) contained in its letter dated September 8, 2023, relating to the above referenced Amendment No. 4 to
Registration Statement on Form S-1 (“Amendment No. 4”). The Company is concurrently submitting an amendment to the
Registration Statement (the “Amendment No. 5”).
For the Staff’s convenience, the Staff’s
comments have been stated below in their entirety in bold, followed by the corresponding responses from the Company. Except for any page
references appearing in the headings or the Staff’s comments (which are references to Amendment No. 4), all page references herein
correspond to the page of the Amendment No. 5. Capitalized terms used but not defined in this letter have the meanings ascribed to such
terms in the Amendment No. 5.
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.
Response: In response to the Staff’s
comment, we have consolidated the industry and market data using the Grand View report commissioned by us and revised the disclosure on
page 69.
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.
Response: In response to the Staff’s
comment, we have disclosed the jurisdictions where each of our directors and director nominees are located on page 123.
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.
Response: We have updated the registration statement to include audited financial
statements for the year ended June 30, 2023.
We thank the Staff for its
review of the foregoing. If you have any questions regarding this matter, please do not hesitate to contact Fang Liu at VCL Law LLP at
fliu@vcllegal.com or by telephone at (703) 919-7285.
Very truly yours,
/s/ Hung To Pau
Hung To Pau, Ph.D.
Chief Executive Officer
cc:
Fang Liu, Esq.
VCL Law LLP