SEC Comment Letter 0000000000-24-003994 to Apollomics Inc. (APLM, APLMW) (CIK 0001944885) (APLM)
Apollomics Inc. (APLM, APLMW) (CIK 0001944885)
Date: April 12, 2024 · CIK: 0001944885 · Accession: 0000000000-24-003994
AI Filing Summary & Sentiment
File numbers found in text: 333-278431
Letter
United States securities and exchange commission logo April 12, 2024 Sanjeev Redkar President Apollomics Inc. 989 E. Hillsdale Blvd., Suite 220 Foster City, CA 94404 Re:Apollomics Inc. Registration Statement on Form F-3 Filed April 1, 2024 File No. 333-278431 Dear Sanjeev Redkar: We have conducted a limited review of your 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. Registration Statement on Form F-3 General 1.We note your cover page states you conduct operations through your wholly owned subsidiary in mainland China. To the extent you do not conduct the majority of your operations in China, please provide us your analysis supporting this. To the extent you conduct the majority of your operations in China, please revise your filing, as applicable, to provide more specific and prominent disclosures about the legal and operational risks associated with China-based companies. For additional guidance, please see the Division of Corporation Finance's Sample Letter to China-Based Companies issued by the Staff in December 2021 and the Sample Letter to Companies Regarding China-Specific Disclosures issued by the Staff in July 2023. In this regard, we note your Amendment Number 4 to the Registration Statement on Form F-4 filed February 21, 2023 appears to address many of the issues identified in the December 2021 letter.
FirstName LastNameSanjeev Redkar Comapany NameApollomics Inc. April 12, 2024 Page 2 FirstName LastName Sanjeev Redkar Apollomics Inc. April 12, 2024 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Daniel Crawford at 202-551-7767 or Tim Buchmiller at 202-551-3635 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Daniel Nussen, Esq.
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United States securities and exchange commission logo
April 12, 2024
Sanjeev Redkar
President
Apollomics Inc.
989 E. Hillsdale Blvd., Suite 220
Foster City, CA 94404
Re:Apollomics Inc.
Registration Statement on Form F-3
Filed April 1, 2024
File No. 333-278431
Dear Sanjeev Redkar:
We have conducted a limited review of your 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.
Registration Statement on Form F-3
General
1.We note your cover page states you conduct operations through your wholly owned
subsidiary in mainland China. To the extent you do not conduct the majority of your
operations in China, please provide us your analysis supporting this. To the extent you
conduct the majority of your operations in China, please revise your filing, as applicable,
to provide more specific and prominent disclosures about the legal and operational risks
associated with China-based companies. For additional guidance, please see the Division
of Corporation Finance's Sample Letter to China-Based Companies issued by the Staff in
December 2021 and the Sample Letter to Companies Regarding China-Specific
Disclosures issued by the Staff in July 2023. In this regard, we note your Amendment
Number 4 to the Registration Statement on Form F-4 filed February 21, 2023 appears to
address many of the issues identified in the December 2021 letter.
FirstName LastNameSanjeev Redkar
Comapany NameApollomics Inc.
April 12, 2024 Page 2
FirstName LastName
Sanjeev Redkar
Apollomics Inc.
April 12, 2024
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Daniel Crawford at 202-551-7767 or Tim Buchmiller at 202-551-3635
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Daniel Nussen, Esq.