SEC Comment Letter 0000000000-23-005360 to Adlai Nortye Ltd. (ANL)
Adlai Nortye Ltd.
Date: May 19, 2023 · CIK: 0001944552 · Accession: 0000000000-23-005360
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United States securities and exchange commission logo
May 19, 2023
Vicky Zhang
Chief Financial Officer
Adlai Nortye Ltd.
c/o PO Box 309, Ugland House
Grand Cayman, KY1-1104
Cayman Islands
Re:Adlai Nortye Ltd.
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted May 11, 2023
CIK No. 0001944552
Dear Vicky Zhang:
We have reviewed your amended draft registration statement and have the following
comment. In this comment, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe our comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to this comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 3 to Draft Registration Statement on Form F-1
Conventions that apply to this prospectus..., page 14
1.We note your response to our prior comment 3 and we re-issue the comment, as your
revised definition of China and the PRC continues to exclude Hong Kong and Macau.
Please revise your definition, as previously requested, to clarify that the legal and
operational risks associated with operating in China also apply to any operations, present
or future, in Hong Kong and Macau.
You may contact Jenn Do at 202-551-3743 or Angela Connell at 202-551-3426 if you
have questions regarding comments on the financial statements and related matters. Please
FirstName LastNameVicky Zhang
Comapany NameAdlai Nortye Ltd.
May 19, 2023 Page 2
FirstName LastName
Vicky Zhang
Adlai Nortye Ltd.
May 19, 2023
Page 2
contact Jimmy McNamara at 202-551-7349 or Laura Crotty at 202-551-7614 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Ke Geng