Correspondence 0001575872-23-001883 from Advanced Biomed Inc. (ADVB)
Advanced Biomed Inc.
Date: Dec. 13, 2023 · CIK: 0001941029 · Accession: 0001575872-23-001883
AI Filing Summary & Sentiment
File numbers found in text: 333-272110
Referenced dates: December 12, 2023
Letter
December 13, 2023
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporate Finance
100 F. Street, N.E.
Washington, D.C. 20549
Attn: Nudrat Salik
Al Pavot
Benjamin Richie
Margaret Schwartz
Re: Advanced Biomed Inc.
Amendment No. 7 to Registration Statement on Form S-1
Filed December 5, 2023
File No. 333-272110
Ladies and Gentlemen,
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 December 12, 2023, relating to the above referenced Amendment No. 7 to Registration Statement on Form S-1 (“Amendment No. 7”). The Company is concurrently submitting an amendment to the Registration Statement (the “Amendment No. 8”).
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.
Response: In response to the Staff’s comment, the Company has provided the updated opinion and consent of AllBright Law Offices in the Amendment No.8.
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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December 13, 2023
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporate Finance
100 F. Street, N.E.
Washington, D.C. 20549
Attn:
Nudrat Salik
Al Pavot
Benjamin Richie
Margaret Schwartz
Re: Advanced Biomed Inc.
Amendment No. 7 to Registration Statement
on Form S-1
Filed December 5, 2023
File No. 333-272110
Ladies and Gentlemen,
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 December 12, 2023, relating to the above referenced Amendment No. 7 to
Registration Statement on Form S-1 (“Amendment No. 7”). The Company is concurrently submitting an amendment to the
Registration Statement (the “Amendment No. 8”).
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.
Response: In response to the Staff’s
comment, the Company has provided the updated opinion and consent of AllBright Law Offices in the Amendment No.8.
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